As discussed above, an investment adviser who is registered with the SEC as of December 31, 2010, must file a revised Brochure by March 31, 2011, to comply with the new Brochure requirements. An annual updating amendment of all other items on the form is also required by March 31, 2011. The revised Brochure or a summary of material changes with an offer to provide the full Brochure must be delivered to clients within sixty (60) days of filing. Currently registered investment advisers with fiscal years ending on December 31, 2010, through April 30, 2011, have until (i) July 31, 2011, to deliver Brochure supplements required by the new Brochure rules to new and prospective clients and (ii) September 30, 2011, to deliver Brochure supplements to existing clients.