Friday, February 25, 2011

District of Columbia Sets Time-Table for IAs Filing New Part 2 of Form ADV

Investment adviser applicants and registrants that follow SEC instructions for completing and filing new Part 2 of Form ADV will be in compliance with District of Columbia requirements. Applicants beginning January 1, 2011 must file through the IARD a new Part 2 with their application, and applicants with a pending application for an IA license, as well as licensed investment advisers beginning January 1, 2011 need to include new Part 2 in their next filing of an amendment or annual updating amendment to Form ADV, whichever filing occurs first. NOTE: All investment advisers must no later than March 31, 2011 file a new Part 2 with the DC Department of Insurance, Securities and Banking.

Deliveries of Form ADV Part 2A and 2B to clients. All advisory firms filing an IA licensing application on or after February 18, 2011 must deliver new Part 2A to their clients immediately on being notified through the IARD that the license is effective. Investment advisers licensed as of December 31, 2010 must deliver new Part 2A to their clients within 60 days of filing the firm brochure on IARD. Investment advisers licensed as of December 31, 2010 whose fiscal year ends on December 31, 2010 through April 30, 2011 will have until July 31, 2011 to deliver new Part 2B to their new and prospective clients, and until September 30, 2011 to deliver brochure supplements to their existing clients. Advisory firms filing an IA licensing application from February 18, 2011 through April 30, 2011 will have until May 1, 2011 to deliver new Part 2B to their new and prospective clients, and until July 1, 2011 to deliver brochure supplements to their existing clients.

Please see http://www.disb.dc.gov/. Click on "securities" under Regulatory Areas and Functions. Then click on "bulletins" under Laws and Regulations.

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