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Colorado Compliance Roundtable: Form ADV Amendments Are Coming: Will You Be Ready?

January 18, 2017

Davis Graham & Stubbs LLP is pleased to invite you to join us for the next installment of the Colorado Compliance Roundtable Breakfast Series. The series is open to all investment adviser compliance professionals and service providers. Each installment is designed to assist with a particular aspect of the evolving regulatory and business landscape.

This series offers a unique opportunity to exchange ideas, questions, and best practices with local compliance professionals, attorneys, and compliance consultants in an interactive, candid, small-group setting.

The Securities and Exchange Commission (SEC) adopted amendments in 2016 to Form ADV and to the books and records rule under the federal Investment Advisers Act of 1940.  The amendments, among other things:

  • Require advisers to provide certain information about separately managed accounts (SMAs), such as the types of assets held and the use of derivatives and borrowing;
  • Streamline and standardize the process of "umbrella" registration of related advisers on one Form ADV;
  • Require advisers to maintain additional materials related to the calculation and distribution of performance information; and
  • Provide ADV disclosure regarding social media, outsourced compliance officers and multiple office locations.

The amendments have a compliance date of October 1, 2017, and will be effective for most investment advisers for their annual update due in late March 2018.  Even though the implementation deadline could seem a ways off, careful planning starting in 2017 can ease the transition.

Issues to be addressed include: 

  • What information do I need to disclose about my SMA arrangements, and should I seek to modify any of my contracts before the disclosure deadline?
  • Who are “related advisers” and what are the benefits and drawbacks of umbrella registration?
  • What additional burdens will be imposed as a result of the extra recordkeeping requirements for performance calculations and will there be any associated effects on subjects like performance portability?
  • What social media issues should I be thinking about in light of the new disclosure requirements?

Our speakers for this program will include:

Event Information

January 19, 2017

1550 17th Street Suite 500 Denver, CO 80202

Breakfast | 7:30 AM Program | 8:00-9:00 AM

Program Materials

Summary of Pay-to-Play Enforcement Actions

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