Registered Investment Advisers who were registered as of December 31, 2010, and who have fiscal years ending December 31, 2010 through April 30, 2011 must deliver brochure supplements (Part 2B Form ADV) to existing clients by September 30, 2011. Advisers should already be delivering brochure supplements to new and prospective clients.

Advisers with fiscal years ending after April 30, 2011, must deliver such brochure supplements within 120 days after the end of their fiscal year. Investment Advisers who filed their applications for registration between January 1, 2011 and April 30, 2011, should already be delivering such brochure supplements to new and prospective clients, as well as existing clients.