Novaworks provides a free Fact Sheet for these amendments to Form ADV and the Investment Advisers Act that has in-depth information. The following is a short overview of the changes being proposed:

Information about Separately Managed Accounts

The proposed amendments would provide the SEC with additional information about an adviser’s separately managed accounts. This information would be provided on Form ADV in Item 5 of Part 1A and Section 5 of Schedule D.

Advisers would be required to update this information when filing their annual updating amendment for Form ADV. Advisers with at least $10 billion in regulatory assets under management attributable to separately managed accounts would report both mid-year and end-year information when filing their annual updating amendment for Form ADV.

Providing Additional Identifying Information on Form ADV

Certain questions would be added to Form ADV and other questions revised. These proposed changes are largely concerned with an adviser’s advisory business, affiliations, and other identifying information.

Permitting Umbrella Registration By Rule

The amendments being proposed would provide umbrella registration where a filing adviser and one or more relying advisers conduct a single private fund advisory business and each relying adviser is controlled by or under common control with the filing adviser. Umbrella registration would only be available to private fund advisers that operate as a single business through multiple legal entities.

The proposed rule would amend the General Instructions for Form ADV to help advisers establish whether an umbrella registration is available to them. These umbrella registrations are currently outlined in staff guidance but would be incorporated into Form ADV’s General Instructions and permitted by rule.

Amending Form ADV for Clarification

Additional amendments are being proposed to make changes to Form ADV for technical or clarifying purposes. These changes are meant to address common questions that filers have when completing Form ADV.

Changes to the Investment Advisers Act Book and Record Rules

The SEC proposes two amendments to the Investment Advisers Act book and record rule (Rule 204-2) that would require investment advisers to maintain additional records of the calculation and distribution of performance information.

Other changes are also part of the proposal. For a detailed look at this proposal, Novaworks provides a free Fact Sheet for the proposed changes to Form ADV and the Investment Advisers Act. 

Comments to the SEC are due August 11, 2015. Comments that have already been received by the SEC are available here: http://www.sec.gov/comments/s7-09-15/s70915.shtml.

Sources:

http://www.sec.gov/rules/proposed/2015/ia-4091.pdf

http://www.sec.gov/news/pressrelease/2015-95.html