SEC Adopts Form ADV Amendments for Affiliated Advisers and Separately Managed Accounts

August 30, 2016

On August 25, 2016, the Securities and Exchange Commission (the “SEC”) adopted amendments to Form ADV to modernize and enhance information reported by investment advisers (the “Amendments” or the “Form ADV Amendments”).

Among other changes, advisers will be required to use a new Schedule R for each relying adviser when using umbrella registration for multiple entities in a single advisory business and will be required to provide additional information about separately managed accounts.  The adopting release also amends Rule 204-2 (the “Books and Records Rule”) under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) to require additional documentation supporting any performance calculations or rates or return in written