The purpose of this paper is to identify and discuss issues impacting Form ADV filings that include new adviser firm brochures and brochure supplements.
Issues were identified by reading against relevant SEC form requirements and guidance, a random sampling of Form ADV amendments filed on the IARD system between January and April 2011.
A host of problems and unusual approaches were found in brochures and supplements created under new Form ADV Part 2, along with numerous issues still challenging advisers on Part 1.
The issues discussed in this paper are among those observed in a limited number of ADV filings selected at random. A more systematic or extensive analysis of filings would likely reveal additional issues that would be fruitful for future discussion.
Advisers and other industry professionals can learn from the issues discussed in this paper and be alert to their potential application to other filings.
This paper provides practical information and insight about Form ADV useful to enhancing an understanding of the form as it has been recently amended.
