Key takeaways

• ‎On June 12, the Securities and Exchange Commission released 23 new frequently asked questions (“FAQs”) on Form ADV to provide guidance on amendments to Form ADV with which investment advisers will need to comply beginning this October.
• Among other things, the FAQs include guidance on (i) the “umbrella registration” approach that many private fund sponsors use to register multiple affiliates (including related managers and general partners) and (ii) the reporting of significant new information concerning separately managed accounts.
• Private fund sponsors should review these FAQs to prepare to comply with amended Form ADV.