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SEC Extends Compliance Date for Certain Advisers to Provide Clients with Brochure Supplements

Advisory | January 6, 2011

The Securities and Exchange Commission has issued a final rule* extending by four months the compliance date for delivery of Part 2B of Form ADV (the brochure supplement).

The extension is intended to provide investment advisers with additional time to implement systems and controls to ensure that each client receives an accurate brochure supplement with respect to the supervised person who provides advice to that client.

The practical effect of the extension is as follows:

Existing Registered Investment Advisers

Investment advisers registered with the SEC on December 31, 2010, and having a fiscal year ending on December 31, 2010, through April 30, 2011, will have until (a) July 31, 2011, to begin delivering brochure supplements to new and prospective clients, and (b) September 30, 2011, to deliver brochure supplements to existing clients.

Newly Registered Investment Advisers

Newly registered investment advisers filing applications for registration with the SEC from January 1, 2011, through April 30, 2011, will have until (a) May 1, 2011, to begin delivering brochure supplements to new and prospective clients, and (b) July 1, 2011, to deliver brochure supplements to existing clients.

The above deadlines replace earlier ones in the extensive rule and Form ADV amendments adopted last July. Click here to view the Katten Client Advisory that discusses these amendments in greater detail.

Other Compliance Deadlines Unchanged

The compliance dates for delivering brochure supplements for both existing SEC registered investment advisers with fiscal years ending after April 30, 2011, and for newly registered investment advisers filing applications for registration after April 30, 2011, remain unchanged.

The SEC is not extending the compliance date for filing and delivering Part 2A of Form ADV (the brochure), which is required for (a) newly registering investment advisers that file for SEC registration beginning on January 1, 2011, and (b) existing SEC registered advisers when they file their annual updating amendments for fiscal years ending on or after December 31, 2010.
 

*The final rule is available on the SEC website at www.sec.gov/rules/final/2010/ia-3129.pdf.

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