Annual Amendment 2018-RIA compliance. Registered Investment Advisors with a December fiscal year end are required to prepare and file an annual updating amendment to their Form ADV within 90 days of your fiscal year end, or by March 31, 2018.
This year, with the annual amendment 2018-RIA compliance, registered investment advisors will be faced with new and more extensive questions on the Form ADV. Generally, the ‘new’ questions center around:
- Reporting your firm’s social media web addresses;
- Providing information about whether your RIA firm outsources your Chief Compliance Officer duties;
- New information about wrap fee programs;
- And, new information to report concerning your ‘separately managed account’ business.
Some registered investment advisors that I have spoken with do not believe the new questions centered around reporting information for ‘separately managed account’ business apply to them.
Investment advisors need to be cautious about this term ‘separately management accounts’ as the Securities and Exchange Commission (SEC) has defined this term very broadly so that it essentially includes all of your individual advisory clients, outside of any private funds, business development companies or mutual funds where your firm may provide investment advice. As a result, the majority of registered investment advisor firms will be impacted by these new questions.
If you have not yet reviewed the new Form ADV you should do so soon to prepare for your firm’s annual amendment 2018-RIA compliance.
Contact Registered Advisor Services today for a free consultation and price quote on assistance with your Annual Amendment 2018-RIA compliance.
