For private fund managers, one troubling aspect of Form ADV had been the calculation of “assets under management” in item 5.F. If securities are less than 50% of the portfolio then the portfolio would not be a securities account. Except for real estate debt funds, most real estate funds would end up with $0. (I’m [...]
Tag Archives | Form ADV
Yes, the SEC Wants Real Estate Fund Managers to Register
Earlier I had pointed out how a real estate fund manager could be considered an investment adviser and have to register with the SEC under the Investment Advisers Act. In the Proposed Changes to Form ADV published on November 19, the SEC has made it clear that real estate funds are part of the mix. [...]
Proposed Changes to Form ADV
The SEC has released its proposed changes to Form ADV to better deal with private fund registration and the exempt, but reporting required of venture capital funds: Release No. IA-3110 The Securities and Exchange Commission is proposing new rules and rule amendments under the Investment Advisers Act of 1940 to implement provisions of the Dodd-Frank [...]
SEC is Changing Form ADV
The SEC is trying to improve Form ADV. I wonder if it takes into account the new registration standards under the Dodd-Frank Act or whether they will need to make another to recognize the new law. From the SEC press Release SEC Approves Disclosure Form Changes to Provide Investors Greater Information About Their Investment Advisers: [...]
SEC Releases Proposed Custody Rules for Investment Advisers
On May 14, the Securities Exchange Commission said they were proposing New Custody Rules for Investment Advisers. They summarized the proposed rules but did not release the actual text of the proposed rules. Now the proposed rules are available in Release No. IA-2876 (.pdf). Comments must be received on or before July 28, 2009. SUMMARY: [...]
Post Your Form ADV
If you are a registered investment adviser you need to file a Form ADV with the SEC. Your Form ADV is searchable on SEC’s Investment Adviser Public Disclosure site. Post a copy of your filed Form ADV on your company’s website and/or link to your Form ADV on the SEC website.It shows you are registered [...]
