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In Plain English A publication of THE SECURITIES LAW GROUP | James E. Grand | February 2016   ANNUAL UPDATING AMENDMENT TO FORM ADV All registered investment advisers—including exempt reporting advisers—are required to file various regulatory and compliance filings throughout the year. THE MOST IMPORTANT OF THEM IS THE ANNUAL UPDATING AMENDMENT ON FORM ADV. […]

As registered investment advisers (“RIAs”) attempt to grow their businesses, they often consider whether to use third-party solicitors. RIAs must take care to understand the compliance obligations they will face when they choose to enter into a solicitation arrangement.

On May 22, 2017, the Department of Labor (DOL) announced that the DOL’s new fiduciary investment advice rule would go into effect on June 9, 2017 (as opposed to April 10, the originally scheduled implementation date). This paper focuses on what the new applicability date means for our clients—separate account managers and private fund managers. Specifically, it addresses what they should start doing now and what they must do before the end of the transition period on December 31, 2017.