On October 1, 2017, the SEC stopped accepting amendments to the “old” Form ADV and are requiring firms to comply with the new changes to the Form ADV, which were approved in August. The red-line edits were posted on the SEC’s website and focus more on topics relating to social media and greater detail regarding how client assets are invested. Registrants will now have to disclose the website addresses of its social media pages where it controls the content. Because detailed disclosures of individual client demographics and investments are now required, the more clients an RIA has, the more burdensome the disclosure process will become. Depending on the RIA’s client base, the new disclosure requirements could be voluminous. The amended Form also requires expanded information regarding “relying advisors” that previously filed under an Umbrella Registration. Under the new Form, relying advisors will separately complete a Schedule R.
A link to the redlined changes to the Form ADV is below.