Key takeaways

• On May 20, the Securities and Exchange Commission (the “SEC”) proposed rules, forms, and amendments to modernize and enhance data reporting requirements for investment advisers and investment companies. The proposals are primarily designed to provide the SEC with the data that it believes that it needs to oversee the asset management industry, including monitoring systemic risks.
• The proposed amendments would codify the “umbrella registration” approach that many private fund sponsors use to register multiple affiliates on Form ADV under the Investment Advisers Act of 1940; however, exempt reporting advisers would not be permitted to use the “umbrella registration” approach.
• In addition, the proposed amendments would require significant new information concerning separately managed accounts to be reported on Form ADV and impose new books and records requirements on advisers relating to performance information.