Compliance Solutions for Investment Advisers

Registration Transition Info From the SEC

SEC-Registered Investment Advisers: Between January 1, 2012 and March 30, 2012, ALL SEC-registered advisers, and advisers who have an application for registration pending with the SEC, must file a Form ADV amendment (annual updating amendment or other-than-annual amendment), completing ALL items on the revised form (including corresponding sections of Schedules A, B, C and D) and indicating with which regulator they should be registered (in Item 2). Please note that ALL SEC-registered advisers must file a Form ADV amendment without regard to when their fiscal year ends (example: advisers with a June fiscal year end must file an other-than-annual amendment between January 1 and March 30, 2012). An adviser should also amend its brochure if any information has become materially inaccurate. Advisers seeking to file other-than-annual amendments to update only limited sections of Form ADV (for example: only the Part 2 brochure or their address in Item 1) must complete ALL questions, including new and revised questions, on Part 1 of the Form ADV. Advisers that must switch from SEC to state registration should mark Item 2.A.(13) and should begin registering with the state(s) to ensure they can withdraw their SEC registration by June 28, 2012. Please see the General Instructions to Form ADV http://www.sec.gov/about/forms/formadv-instructions.pdf and the SEC’s recently adopted rules for more information (IA-3221 and IA-3222, June 22, 2011, on http://www.sec.gov/rules/final.shtml).

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