Performance Record Retention
New SEC requirements significantly expand public disclosures by registered investment advisers for their SMA businesses. The requirements take effect Oct 1, 2017. The SEC also confirmed provisions for "umbrella registration" of related advisers and generally overhauled many questions on Form ADV. There is time to act, but many to-do's follow from the new rules. Our webinar will cover practical tips for the coming compliance challenges.
You can download a full copy of the slides from this webinar.
Full video transcript available below:
Okay. As I said as the outset, remember that we have four main changes embodied in the rulemaking. The SMA rules, which we have gone through, umbrella registration, which we have discussed, the miscellaneous, the broad sets of things they tinkered with in the form, which Pat has just walked us through, and then two new rules around performance records, and that's where we are here. Now, also as I said at the outset, these rules have basically been greeted with acceptance by the industry, because the industry says, "I largely keep this data, and I largely keep these records in the course of my business anyway." What are they. First, new rule, 204-2, which is the recordkeeping rule, and new paragraph A16 inside that rule. It used to be that you kept records referring to performance claims if they were circulated to ten or more people.
|This webinar was co-hosted with Shearman & Sterling LP. To learn more visit www.shearman.com