The SEC adopted today a number of rulemakings and interpretations focused on bringing greater quality and transparency to the relationships between retail investors and investment advisors and broker-dealers. Of special interest to investment advisors is a new Form CRS Relationship Summary and an interpretation under the Investment Advisers Act of 1940 regarding the fiduciary duty of investment advisors.
The SEC recently adopted rules, originally proposed in May 2015, that expand the disclosure requirements in Form ADV, Part 1A. These amendments will be effective 60 days after the publication in the Federal Register and investment advisors will need to start complying starting on October 1, 2017. This means that if your firm's fiscal year ends on December 31, 2017, you will need to comply with the Form ADV changes no later than your annual amendment filing in March 2018. A summary of the more substantive enhancements to Part 1A is provided below.
An SEC mock audit is an important tool that your registered investment advisor can utilize to help ensure that your firm is in compliance and your employees are prepared the next time the SEC appears at your door.