Key takeaways

• On August 25th, the Securities and Exchange Commission (the “SEC”) adopted final rules, forms and amendments to modernize and enhance data reporting requirements for investment advisers. The amendments are primarily designed to provide the SEC with the data that it believes it needs to oversee the asset management industry, including monitoring systemic risks and assisting the SEC staff in examination and enforcement efforts. 
• Among other things, the amendments: (i) 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; (ii) require significant new information concerning separately managed accounts to be reported on Form ADV; and (iii) impose new books and records requirements on advisers relating to performance information. The amendments also require a registrant to report if it outsources its chief compliance officer function. 
• The compliance date for the amendments is October 1, 2017. Therefore, any initial registrations or amendments filed on Form ADV on or after that date will be required to comply with the amended Form.