New form ADV Part 2: post‐filing post‐mortem and more fun with Part 1

Abstract

Purpose – The purpose of this paper is to identify and discuss issues impacting Form ADV filings that include new adviser firm brochures and brochure supplements.Design/methodology/approach – 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.Findings – 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.Research limitations/implications – 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.Practical implications – Advisers and other industry professionals can learn from the issues discussed in this paper and be alert to their potential application to oth...