Recently, I wrote about the SEC’s adoption of amendments to the Form ADV Part 1 as of August 25, 2016. Then, I wrote a second blog reminding registered investment advisors of those changes and to notify you that the changes to the Form ADV Part 1 go into effect as of October 1, 2017. Originally, that meant if you needed to amend your Form ADV Part 1 for any reason on or after October 1, 2017, investment advisors would need to provide responses to the new questions applicable to your firm’s business model.
Today, the SEC released an information update with additional guidance on responding to these ‘new’ questions. Click here for the Information Update.
- The SEC’s guidance is if you need to file an other-than-annual-amendment to make a change to your Form ADV Part 1 on or after October 1, 2017, but before your next annual amendment, and you do not have the additional information needed to respond to the ‘new’ questions in Item 5, and Schedule D sections, you can simply answer with “0” and provide a brief explanation in the Miscellaneous section of the Schedule D that a placeholder value of “0” was entered.
This new guidance helps to provide additional time to gather the data needed to comply with the new questions.
