Investment Advisers Regulation - Registration and Reporting - Comment Letter - American Bar Association - January 31, 2011

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Dodd-Frank Timeline, Rules Implementing Amendments to the Investment Advisers Act of 1940, SEC
Final Rule Issue Effective Date Compliance Date
July 19, 2011 September 19, 2011 March 30, 2012

Rules Implementing Amendments to the Investment Advisers Act of 1940
January 31, 2011

The comment letter provides:

  • recommendations for an exempt reporting mid-sized adviser;
  • definition of the term "client;"
  • analysis of state examination affirmations and assets under management calculation;
  • concerns regarding switching to and from registration with the Commission, and also solutions including deleting the $5 million buffer in Rule 203A-1, changing the application filing deadline to 180 days of an adviser's fiscal year end and providing an adviser switching from Commission registration to state registration 270 days from its fiscal year end to do so;
  • revisions to transitional rules for Section 410;
  • support for the continued use of the Investment Adviser Registration Depositary (IARD) system for Form ADV filings, and other reporting recommendations; and
  • a look at the information asked of advisers through Form ADV.


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