November 2019

The U.S. Securities and Exchange Commission (“SEC”) announced on November 4, 2019 that it has voted to propose amendments to modernize the rules under the Investment Advisers Act of 1940, as amended (“Advisers Act”) addressing investment adviser advertisements and payments to solicitors. The proposed amendments (all 507 pages) are intended to update these rules to reflect changes in technology, the expectations of investors seeking advisory services, and the evolution of industry practices.

Over the past month, new guidance, and resources on the topics of custody, investment adviser compensation, and Form ADV disclosures have been issued. Below we highlight each topic and cite the source for easy reference. We welcome questions from our clients relative to these important matters.