On July 21, 2010, the Securities and Exchange Commission (“SEC”) adopted amendments to cheap viagra brand Part 2 of Form ADV that became effective October 12, 2010. Part 2A of Form ADV, the “firm brochure,” contains information about the advisory firm itself. Part 2B of Form ADV, the “brochure supplement,” contains information about the advisory personnel.
On December 28, 2010, the SEC issued a four-month extension for the Part 2B compliance dates. The new compliance dates for Part 2B are as follows:
- New IAs – All newly registered IAs filing their applications for registration with the SEC from January 1, 2011 through April 30, 2011, have until May 1, 2011 to begin delivering Part 2B to new and prospective clients. These advisers have until July 1, 2011 to deliver Part 2B to existing clients. The compliance dates for delivering Part 2B for newly-registered IAs filing applications for registration after April 30, 2011 remain unchanged.
- Existing registered IAs – All IAs registered with the SEC as of December 31, 2010, and having a fiscal year ending on December 31, 2010 through April 30, 2011, have until July 31, 2011, to begin delivering Part 2B to new and prospective clients. These advisers have until September 30, 2011 to deliver Part 2B to existing clients. The compliance dates for delivering Part 2B for existing registered IAs with fiscal years ending after April 30, 2011 remain unchanged.
The compliance dates for Part 2A remain unchanged. More information about the compliance dates initially set by the SEC are available here.
For the full SEC release, please see SEC Extends Compliance Deadline for ADV Part 2.
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Bart Mallon Esq. is a hedge fund attorney and provides hedge fund compliance services through Cole-Frieman & Mallon LLP. He can be reached directly at 415-868-5345.