A recent administrative proceeding involving a dual-registered investment advisor and broker-dealer demonstrates the importance of providing full and fair disclosure regarding any material conflict of interest and achieving best execution on behalf of advisory clients.
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.