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”
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.
AdvisorCounsel is a blog discussing issues relevant to the investment adviser community. While the focus is on issues pertinent to investment advisers to separate accounts (more specifically, wealth managers), this blog will address issues that extend to institutional managers, private fund managers, advisers to registered investment companies, and roboadvisers. AdvisorCounsel is a compilation of theContinue reading “An Introduction to AdvisorCounsel”