This year, the SEC has a new Valentine’s Day gift for Private Fund Advisors: Your Form ADV Parts 1 and 2 are due. Thanks to Dodd-Frank [and Madoff fallout], many firms that previously could avoid registering with the SEC through the Investment Advisers Act of 1940’s “private adviser” exemption will no longer enjoy this immunity. Now, most private fund advisors with at least $150 million assets under management must register by March 30, 2012 — and file their Form ADV by February 14 to allow proper processing time.
With only a few weeks before this due date, we know a lot of private fund advisors are scrambling to complete this process for the first time, but it’s not too late to find help. If you aren’t finished — or are concerned about mistakes and omissions — Oyster Consulting can work with you to:
- Interview your leaders.
- Craft your responses to ADV part 1.
- Create your ADV part 2.
- Draft policies, procedures and a code of ethics.
- Complete the registration process.
- Prepare for a visit from the SEC.
Oyster’s consultants are diligent, experienced guides who can help you comply with this new regulatory change for private fund advisors — but we aren’t miracle workers. So, we ask that any interested firms contact us by January 31, to allow adequate time to thoroughly support you.
Even if you prefer to prepare for these new requirements alone, don’t hesitate to call me at 804.965.5403 with any questions or concerns. I might not always be by my phone, but I will always call you back.