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SEC Disclosures Guide: Enhanced Identification



We at Shearman & Sterling were pleased to have the opportunity to present our thoughts on “SEC Public Disclosures - A Guide for Investment Advisers” at the MyComplianceOffice Webinar on October 13. We had an enthusiastic crowd and some lively exchanges. We’d like to summarize the main points of our presentation here in a five-part series.

Yesterday we discussed, "Umbrella Registration". Today we provide an update on the expanded advisory business identification data requirement component,“Enhanced Identification Process”.

The SEC has expanded advisory business identification data requirements on Form ADV for both RIAs and Exempt Reporting Advisers. In general, the enhanced disclosure pertains to:

1) All CIK numbers, regardless of public reporting status of investment adviser.

2) Websites and accounts for social media platforms which are maintained and controlled by       investment adviser for purpose of promoting its advisory business.

3) Number of offices at which an investment adviser conducts advisory activities and details         concerning its advisory activities conducted at its 25 largest offices.

4) Outsourcing arrangements for the chief compliance officer function.

5) More precise information regarding the balance sheet assets of large investment advisers.

6) More precise information regarding the advisory business of an investment adviser with           respect to number of clients, types of clients and RAUM attributable to client types.

This is the third post in our five-part series titled “SEC Public Disclosures - A Guide for Investment advisers". Click here to view part 4, "Performance Record Retention". Alternatively you can download the full report here.