SEC Form ADV Amendments and Investment Adviser Recordkeeping Rules: Compliance Deadline Quickly Approaching

• Published in: The Investment Lawyer Vol. 24; no. 9; p. 21
• Main Authors: Perlow, Mark D, Sherman, Michael L, Schleppegrell, Christine Ayako, O'Neill, Melissa A
• Format: Trade Publication Article
• Language: English
• Published: Englewood Cliffs Aspen Publishers, Inc 01.09.2017
• Subjects: Balance sheets; Borrowing; Compliance; Deadlines; Equity; Federal regulation; Investment advisors; Reporting requirements; SEC regulations; Securities regulations; Social networks; United States > US
• ISSN: 1075-4512

[...]advisers will be required to comply with certain recordkeeping requirements related to written communications of performance or securities recommendations to any person. [...]of the reporting required by these form revisions, an adviser may need to report data points from before the compliance date. [...]the SEC amended rule 204-2(a)(7) to add that advisers must maintain originals of all written communications received and copies of written communications sent relating to the performance or rate of return of any or all managed accounts or securities recommendations. 2 The categories are: (i) exchange-traded equity securities, (ii) non-exchange-traded equity securities, (iii) US government/agency bonds, (iv) US state and local bonds, (v) sovereign bonds, (vi) investment grade corporate bonds, (vii) non-investment grade corporate bonds, (viii) derivatives, (ix) securities issued by registered investment companies or business development companies, (x) securities issued by pooled investment vehicles (other than registered investment companies), (xi) cash and cash equivalents, and (xii) other.