On Jun. 12, 2017, SEC issued FAQ on Form ADV related to Apr. 2016 final rule changes.
- Do not report social media account, where an unaffiliated distributor controls content.
- If another person pays your CCO, only report if paid for providing services to your firm.
- Only report over $1bn in total assets if on adviser’s balance sheet, at last day year end.
- Treat each wrap fee program participant for which provide advisory service, as a client.
- Pooled investment vehicles include, but not limited to, private funds, e.g. UCITS in EU.
- Borrowings on SMA include traditional lending, secured, synthetic borrowings e.g., TRS.
- If custodian has 10% or SMA clients’ assets, do not report if they used a “sub-custodian”.
- Withdrew Jan. 2012 relief to ABA on umbrella funds, as superseded by 2017 Form ADV.
- Non-resident partner of relying adviser should file Form ADV-NR, even if resident in US.