Division of Investment Management Releases FAQs on Financial Conflicts for RIAs

On Friday, October 18, 2019, the U.S. Securities and Exchange Commission’s Division of Investment Management released “Frequently Asked Questions Regarding Disclosure of Certain Financial Conflicts Related to Investment Adviser Compensation.” The FAQs discuss certain compensation arrangements and related disclosure obligations arising from both the investment adviser’s fiduciary duty and Form ADV. Nothing in the FAQsContinue reading “Division of Investment Management Releases FAQs on Financial Conflicts for RIAs”

Form ADV Annual Amendment Updates: Best Practices and Recent Trends in Completing Form ADV

Here is a discussion on completing Form ADV and submitting annual updating amendments. We discuss: the timeline for submitting annual updating amendments, how to collect data, seeking input from operations and business units, taking positions on ambiguous questions, identifying conflicts of interest and adequately disclosing them, and recent trends in Form ADV Part 2A disclosure.