Proposed Changes

APPENDIX A

FORM ADV (Paper Version)
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UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION
AND
REPORT FORM BY EXEMPT REPORTING ADVISERS

Form ADV: General Instructions

Read these instructions carefully before filing Form ADV. Failure to follow these instructions,
properly complete the form, or pay all required fees may result in your application or report
being delayed or rejected.
In these instructions and in Form ADV, “you” means the investment adviser (i.e., the advisory
firm). If you are a “separately identifiable department or division” (SID) of a bank, “you” means
the SID, rather than your bank, unless the instructions or the form provide otherwise. If you are
a private fund adviser filing an umbrella registration, “you” means the filing adviser and each
relying adviser, unless the instructions or the form provide otherwise. The information in Items
1, 2, 3 and 10 (including corresponding schedules) should be provided for the filing adviser only.
Terms that appear in italics are defined in the Glossary of Terms to Form ADV.
1.

Where can I get more information on Form ADV, electronic filing, and the IARD?
The SEC provides information about its rules and the Advisers Act on its website:
.
NASAA provides information about state investment adviser laws and state rules, and how to
contact a state securities authority, on its website: .
FINRA provides information about the IARD and electronic filing on the IARD website:
.

2.

What is Form ADV used for?
Investment advisers use Form ADV to:
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Register with the Securities and Exchange Commission
Register with one or more state securities authorities
Amend those registrations;

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Report to the SEC as an exempt reporting adviser
Report to one or more state securities authorities as an exempt reporting adviser
Amend those reports; and
Submit a final report as an exempt reporting adviser

Form ADV: General Instructions
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How is Form ADV organized?
Form ADV contains four parts:
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Part 1A asks a number of questions about you, your business practices, the persons who
own and control you, and the persons who provide investment advice on your behalf.
o All advisers registering with the SEC or any of the state securities authorities
must complete Part 1A.
o Exempt reporting advisers (that are not also registering with any state securities
authority) must complete only the following Items of Part 1A: 1, 2, 3, 6, 7, 10,
and 11, as well as corresponding schedules. Exempt reporting advisers that are
registering with any state securities authority must complete all of Form ADV.
Part 1A also contains several supplemental schedules. The items of Part 1A let you know
which schedules you must complete.
o Schedule A asks for information about your direct owners and executive officers.
o Schedule B asks for information about your indirect owners.
o Schedule C is used by paper filers to update the information required by
Schedules A and B (see Instruction 18).
o Schedule D asks for additional information for certain items in Part 1A.
o Schedule R asks for additional information about relying advisers.
o Disclosure Reporting Pages (or DRPs) are schedules that ask for details about
disciplinary events involving you or your advisory affiliates.

•

Part 1B asks additional questions required by state securities authorities. Part 1B
contains three additional DRPs. If you are applying for SEC registration or are registered
only with the SEC, you do not have to complete Part 1B. (If you are filing electronically
and you do not have to complete Part 1B, you will not see Part 1B.)

•

Part 2A requires advisers to create narrative brochures containing information about the
advisory firm. The requirements in Part 2A apply to all investment advisers registered
with or applying for registration with the SEC, but do not apply to exempt reporting
advisers.

• Part 2B requires advisers to create brochure supplements containing information about
certain supervised persons. The requirements in Part 2B apply to all investment advisers
registered with or applying for registration with the SEC, but do not apply to exempt
reporting advisers.
4.

When am I required to update my Form ADV?
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SEC- and State-Registered Advisers:
o Annual updating amendments: You must amend your Form ADV each year by
filing an annual updating amendment within 90 days after the end of your fiscal

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year. When you submit your annual updating amendment, you must update your
responses to all items, including corresponding sections of Schedules A, B, C, and
D and all sections of Schedule R for each relying adviser. You must submit your
summary of material changes required by Item 2 of Part 2A either in the brochure
(cover page or the page immediately thereafter) or as an exhibit to your brochure.
o Other-than-annual amendments: In addition to your annual updating amendment,
if you are registered with the SEC or a state securities authority, you must amend
your Form ADV, including corresponding sections of Schedules A, B, C, D and
R, by filing additional amendments (other-than-annual amendments) promptly if:
o you are adding or removing a relying adviser as part of your umbrella
registration
o information you provided in response to Items 1 (except 1.O), 3, 9 (except
9.A.(2), 9.B.(2), 9.E., and 9.F.), or 11 of Part 1A or Items 1, 2.A. through
2.F., or 2.I. of Part 1B or Sections 1 or 3 of Schedule R becomes
inaccurate in any way;
o information you provided in response to Items 4, 8, or 10 of Part 1A, or
Item 2.G. of Part 1B, or Section 10 of Schedule R becomes materially
inaccurate; or
o information you provided in your brochure becomes materially inaccurate
(see note below for exceptions)
Notes: Part 1: If you are submitting an other-than-annual amendment, you are
not required to update your responses to Items 2, 5, 6, 7, 9.A.(2), 9.B.(2),
9.E., 9.F., or 12 of Part 1A, Items 2.H. or 2.J. of Part 1B, or Section 2 of
Schedule R even if your responses to those items have become inaccurate.
Part 2: You must amend your brochure supplements (see Form ADV, Part
2B) promptly if any information in them becomes materially inaccurate.
If you are submitting an other-than-annual amendment to your brochure,
you are not required to update your summary of material changes as
required by Item 2. You are not required to update your brochure between
annual amendments solely because the amount of client assets you manage
has changed or because your fee schedule has changed. However, if you
are updating your brochure for a separate reason in between annual
amendments, and the amount of client assets you manage listed in
response to Item 4.E or your fee schedule listed in response to Item 5.A
has become materially inaccurate, you should update that item(s) as part of
the interim amendment.
•

If you are an SEC-registered adviser, you are required to file your
brochure amendments electronically through IARD. You are not
required to file amendments to your brochure supplements with the
SEC, but you must maintain a copy of them in your files.

Form ADV: General Instructions
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If you are a state-registered adviser, you are required to file your
brochure amendments and brochure supplement amendments with
the appropriate state securities authorities through IARD.

Exempt reporting advisers:
o Annual Updating Amendments: You must amend your Form ADV each year by
filing an annual updating amendment within 90 days after the end of your fiscal
year. When you submit your annual updating amendment, you must update your
responses to all required items, including corresponding sections of Schedules A,
B, C and D.
o Other-than-Annual Amendments: In addition to your annual updating
amendment, you must amend your Form ADV by filing additional amendments
(other-than-annual amendments) promptly if:
o information you provided in response to Items 1, 3, or 11 becomes
inaccurate in any way; or
o information you provided in response to Item 10 becomes materially
inaccurate.

Failure to update your Form ADV, as required by this instruction, is a violation of SEC
rules or similar state rules and could lead to your registration being revoked.
5.

What is SEC umbrella registration and how can I satisfy the requirements of filing
an umbrella registration?
An umbrella registration is a single registration by a filing adviser and one or more relying
advisers who advise only private funds and certain separately managed account clients that
are qualified clients and collectively conduct a single advisory business. Absent other facts
suggesting that the filing adviser and relying adviser(s) conduct different businesses,
umbrella registration is available under the following circumstances:
i.

The filing adviser and each relying adviser advise only private funds and clients in
separately managed accounts that are qualified clients and are otherwise eligible to invest
in the private funds advised by the filing adviser or a relying adviser and whose accounts
pursue investment objectives and strategies that are substantially similar or otherwise
related to those private funds.

ii.

The filing adviser has its principal office and place of business in the United States and,
therefore, all of the substantive provisions of the Advisers Act and the rules thereunder
apply to the filing adviser’s and each relying adviser’s dealings with each of its clients,
regardless of whether any client or the filing adviser or relying adviser providing the
advice is a United States person.

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iii.

Each relying adviser, its employees and the persons acting on its behalf are subject to the
filing adviser’s supervision and control and, therefore, each relying adviser, its employees
and the persons acting on its behalf are “persons associated with” the filing adviser (as
defined in section 202(a)(17) of the Advisers Act).

iv.

The advisory activities of each relying adviser are subject to the Advisers Act and the
rules thereunder, and each relying adviser is subject to examination by the SEC.

v.

The filing adviser and each relying adviser operate under a single code of ethics adopted
in accordance with SEC rule 204A-1 and a single set of written policies and procedures
adopted and implemented in accordance with SEC rule 206(4)-(7) and administered by a
single chief compliance officer in accordance with that rule.
To satisfy the requirements of Form ADV while using umbrella registration the filing
adviser must sign, file, and update as required, a single Form ADV (Parts 1 and 2) that
relates to, and includes all information concerning, the filing adviser and each relying adviser
(e.g., disciplinary information and ownership information), and must include this same
information in any other reports or filings it must make under the Advisers Act or the rules
thereunder (e.g., Form PF). The filing adviser and each relying adviser must not be
prohibited from registering with the SEC by section 203A of the Advisers Act (i.e. the filing
adviser and each relying adviser must individually qualify for SEC registration).

Unless otherwise specified, references to “you” in Form ADV refer to both the filing adviser
and each relying adviser. The information in Items 1, 2, 3 and 10 (including corresponding
schedules) should be provided for the filing adviser only. A separate Schedule R should be
completed for each relying adviser. References to “you” in Schedule R refer to the relying
adviser only.
A filing adviser applying for registration with the SEC should complete a Schedule R for
each relying adviser. If you are a filing adviser registered with the SEC and would like to add
or delete relying advisers from an umbrella registration, you should file an other-than-annual
amendment and add or delete Schedule Rs as needed.
Note: Umbrella registration is not available to exempt reporting advisers.
6.

Where do I sign my Form ADV application or amendment?
You must sign the appropriate Execution Page. There are three Execution Pages at the end
of the form. Your initial application, your initial report (in the case of an exempt reporting
adviser), and all amendments to Form ADV must include at least one Execution Page.
•

If you are applying for or are amending your SEC registration, or if you are reporting as
an exempt reporting adviser or amending your report, you must sign and submit either a:
o Domestic Investment Adviser Execution Page, if you (the advisory firm) are a
resident of the United States; or

Form ADV: General Instructions

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o Non-Resident Investment Adviser Execution Page, if you (the advisory firm) are
not a resident of the United States.
•

7.

If you are applying for or are amending your registration with a state securities authority,
you must sign and submit the State-Registered Investment Adviser Execution Page.
Who must sign my Form ADV or amendment?

The individual who signs the form depends upon your form of organization:
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For a sole proprietorship, the sole proprietor.
For a partnership, a general partner.
For a corporation, an authorized principal officer.
For a “separately identifiable department or division” (SID) of a bank, a principal officer
of your bank who is directly engaged in the management, direction, or supervision of
your investment advisory activities.
For all others, an authorized individual who participates in managing or directing your
affairs.

The signature does not have to be notarized, and in the case of an electronic filing, should be
a typed name.
8.

How do I file my Form ADV?
Complete Form ADV electronically using the Investment Adviser Registration Depository
(IARD) if:
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You are filing with the SEC (and submitting notice filings to any of the state securities
authorities), or

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You are filing with a state securities authority that requires or permits advisers to submit
Form ADV through the IARD.
Note: SEC rules require advisers that are registered or applying for registration with the
SEC, or that are reporting to the SEC as an exempt reporting adviser, to file
electronically through the IARD system. See SEC rules 203-1 and 204-4.

To file electronically, go to the IARD website (), which contains detailed
instructions for advisers to follow when filing through the IARD.
Complete Form ADV (Paper Version) on paper if:
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You are filing with the SEC or a state securities authority that requires electronic filing,
but you have been granted a continuing hardship exemption. Hardship exemptions are
described in Instruction 17.

Form ADV: General Instructions
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You are filing with a state securities authority that permits (but does not require)
electronic filing and you do not file electronically.
How do I get started filing electronically?

First, obtain a copy of the IARD Entitlement Package from the following website:
. Second, request access to the IARD system for your
firm by completing and submitting the IARD Entitlement Package. The IARD Entitlement
Package must be submitted on paper. Mail the forms to: FINRA Entitlement Group, P.O.
Box 9495, Gaithersburg, MD 20898-9495.
When FINRA receives your Entitlement Package, they will assign a CRD number
(identification number for your firm) and a user I.D. code and password (identification
number and system password for the individual(s) who will submit Form ADV filings for
your firm). Your firm may request an I.D. code and password for more than one individual.
FINRA also will create a financial account for you from which the IARD will deduct filing
fees and any state fees you are required to pay. If you already have a CRD account with
FINRA, it will also serve as your IARD account; a separate account will not be established.
Once you receive your CRD number, user I.D. code and password, and you have funded your
account, you are ready to file electronically.
Questions regarding the Entitlement Process should be addressed to FINRA at 240.386.4848.
10.

If I am applying for registration with the SEC, or amending my SEC registration,
how do I make notice filings with the state securities authorities?
If you are applying for registration with the SEC or are amending your SEC registration, one
or more state securities authorities may require you to provide them with copies of your SEC
filings. We call these filings “notice filings.” Your notice filings will be sent electronically
to the states that you check on Item 2.C. of Part 1A. The state securities authorities to which
you send notice filings may charge fees, which will be deducted from the account you
establish with FINRA. To determine which state securities authorities require SECregistered advisers to submit notice filings and to pay fees, consult the relevant state
investment adviser law or state securities authority. See General Instruction 1.
If you are granted a continuing hardship exemption to file Form ADV on paper, FINRA will
enter your filing into the IARD and your notice filings will be sent electronically to the state
securities authorities that you check on Item 2.C. of Part 1A.

11.

I am registered with a state. When must I switch to SEC registration?
If at the time of your annual updating amendment you meet at least one of the requirements for
SEC registration in Item 2.A.(1) to (12) of Part 1A, you must apply for registration with the
SEC within 90 days after you file the annual updating amendment. Once you register with the

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SEC, you are subject to SEC regulation, regardless of whether you remain registered with one
or more states. See SEC rule 203A-1(b)(2). Each of your investment adviser representatives,
however, may be subject to registration in those states in which the representative has a place
of business. See Advisers Act section 203A(b)(1); SEC rule 203A-3(a). For additional
information, consult the investment adviser laws or the state securities authority for the
particular state in which you are “doing business.” See General Instruction 1.
12.

I am registered with the SEC. When must I switch to registration with a state
securities authority?
If you check box 13 in Item 2.A. of Part 1A to report on your annual updating amendment
that you are no longer eligible to register with the SEC, you must withdraw from SEC
registration within 180 days after the end of your fiscal year by filing Form ADV-W. See
SEC rule 203A-1(b)(2). You should consult state law or the state securities authority for the
states in which you are “doing business” to determine if you are required to register in these
states. See General Instruction 1. Until you file your Form ADV-W with the SEC, you will
remain subject to SEC regulation, and you also will be subject to regulation in any states
where you register. See SEC rule 203A-1(b)(2).

13.

14.

I am an exempt reporting adviser. When must I submit my first report on Form
ADV?
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All exempt reporting advisers:
You must submit your initial Form ADV filing within 60 days of relying on the
exemption from registration under either section 203(l) of the Advisers Act as an adviser
solely to one or more venture capital funds or section 203(m) of the Advisers Act because
you act solely as an adviser to private funds and have assets under management in the
United States of less than $150 million.

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Additional instruction for advisers switching from being registered to being exempt
reporting advisers:
If you are currently registered as an investment adviser (or have an application for
registration pending) with the SEC or with a state securities authority, you must file a
Form ADV-W to withdraw from registration in the jurisdictions where you are switching.
You must submit the Form ADV-W before submitting your first report as an exempt
reporting adviser.
I am an exempt reporting adviser. Is it possible that I might be required to also
register with or submit a report to a state securities authority?

Yes, you may be required to register with or submit a report to one or more state securities
authorities. If you are required to register with one or more state securities authorities, you
must complete all of Form ADV. See General Instruction 3. If you are required to submit a
report to one or more state securities authorities, check the box(es) in Item 2.C. of Part 1A
next to the state(s) you would like to receive the report. Each of your investment adviser
representatives may also be subject to registration requirements. For additional information

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about the requirements that may apply to you, consult the investment adviser laws or the state
securities authority for the particular state in which you are “doing business.” See General
Instruction 1.
15.

What do I do if I no longer meet the definition of an “exempt reporting adviser”?
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Advisers Switching to SEC Registration:
o You may no longer be an exempt reporting adviser and may be required to register
with the SEC if you wish to continue doing business as an investment adviser. For
example, you may be relying on section 203(l) and wish to accept a client that is not
a venture capital fund as defined in SEC rule 203(l)-1, or you may have been
relying on SEC rule 203(m)-1 and reported in Section 2.B. of Schedule D to your
annual updating amendment that you have private fund assets of $150 million or
more.


If you are relying on section 203(l), unless you qualify for another
exemption, you would violate the Advisers Act’s registration requirement if
you accept a client that is not a venture capital fund as defined in SEC rule
203(l)-1 before the SEC approves your application for registration. You
must submit your final report as an exempt reporting adviser and apply for
SEC registration in the same filing.



If you were relying on SEC rule 203(m)-1 and you reported in Section
2.B. of Schedule D to your annual updating amendment that you have
private fund assets of $150 million or more, you must register with the
SEC unless you qualify for another exemption. If you have complied with
all SEC reporting requirements applicable to an exempt reporting adviser
as such, you have up to 90 days after filing your annual updating
amendment to apply for SEC registration, and you may continue doing
business as a private fund adviser during this time. You must submit your
final report as an exempt reporting adviser and apply for SEC registration
in the same filing. Unless you qualify for another exemption, you would
violate the Advisers Act’s registration requirement if you accept a client
that is not a private fund during this transition period before the SEC
approves your application for registration, and you must comply with all
SEC reporting requirements applicable to an exempt reporting adviser as
such during this 90-day transition period. If you have not complied with
all SEC reporting requirements applicable to an exempt reporting adviser
as such, this 90-day transition period is not available to you. Therefore, if
the transition period is not available to you, and you do not qualify for
another exemption, your application for registration must be approved by
the SEC before you meet or exceed SEC rule 203(m)-1’s $150 million
asset threshold.

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o You will be deemed in compliance with the Form ADV filing and reporting
requirements until the SEC approves or denies your application. If your application
is approved, you will be able to continue business as a registered adviser.
o If you register with the SEC, you may be subject to state notice filing requirements.
To determine these requirements, consult the investment adviser laws or the state
securities authority for the particular state in which you are “doing business.” See
General Instruction 1.
Note: If you are relying on SEC rule 203(m)-1 and you accept a client that is not a private
fund, you will lose the exemption provided by SEC rule 203(m)-1 immediately. To avoid
this result, you should apply for SEC registration in advance so that the SEC has approved
your registration before you accept a client that is not a private fund.
The 90-day transition period described above also applies to investment advisers with their
principal offices and places of business outside of the United States with respect to their
clients who are United States persons (e.g., the adviser would not be eligible for the 90-day
transition period if it accepted a client that is a United States person and is not a private
fund).
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Advisers Not Switching to SEC Registration:
o You may no longer be an exempt reporting adviser but may not be required to
register with the SEC or may be prohibited from doing so. For example, you may
cease to do business as an investment adviser, become eligible for an exemption
that does not require reporting, or be ineligible for SEC registration. In this case,
you must submit a final report as an exempt reporting adviser to update only Item
1 of Part 1A of Form ADV.
o You may be subject to state registration requirements. To determine these
requirements, consult the investment adviser laws or the state securities authority
for the particular state in which you are “doing business.” See General Instruction
1.

16.

Are there filing fees?
Yes. These fees go to support and maintain the IARD. The IARD filing fees are in addition
to any registration or other fee that may be required by state law. You must pay an IARD
filing fee for your initial application, your initial report, and each annual updating
amendment. There is no filing fee for an other-than-annual amendment, a final report as an
exempt reporting adviser, or Form ADV-W. The IARD filing fee schedule is published at
; ; and .
If you are submitting a paper filing under a continuing hardship exemption (see Instruction
17), you are required to pay an additional fee. The amount of the additional fee depends on
whether you are filing Form ADV or Form ADV-W. (There is no additional fee for filings

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made on Form ADV-W.) The hardship filing fee schedule is available by contacting FINRA
at 240.386.4848.
17.

What if I am not able to file electronically?
If you are required to file electronically but cannot do so, you may be eligible for one of two
types of hardship exemptions from the electronic filing requirements.
•

A temporary hardship exemption is available if you file electronically, but you
encounter unexpected difficulties that prevent you from making a timely filing with the
IARD, such as a computer malfunction or electrical outage. This exemption does not
permit you to file on paper; instead, it extends the deadline for an electronic filing for
seven business days. See SEC rules 203-3(a) and 204-4(e).

•

A continuing hardship exemption may be granted if you are a small business and you
can demonstrate that filing electronically would impose an undue hardship. You are a
small business, and may be eligible for a continuing hardship exemption, if you are
required to answer Item 12 of Part 1A (because you have assets under management of
less than $25 million) and you are able to respond “no” to each question in Item 12. See
SEC rule 0-7.
If you have been granted a continuing hardship exemption, you must complete and
submit the paper version of Form ADV to FINRA. FINRA will enter your responses into
the IARD. As discussed in General Instruction 16, FINRA will charge you a fee to
reimburse it for the expense of data entry.

18.

I am eligible to file on paper. How do I make a paper filing?
When filing on paper, you must:
•
•
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Type all of your responses.
Include your name (the same name you provide in response to Item 1.A. of Part 1A) and
the date on every page.
If you are amending your Form ADV:
o complete page 1 and circle the number of any item for which you are changing
your response.
o include your SEC 801-number (if you have one), or your 802-number (if you have
one), and your CRD number (if you have one) on every page.
o complete the amended item in full and circle the number of the item for which
you are changing your response.
o to amend Schedule A or Schedule B, complete and submit Schedule C.

Where you submit your paper filing depends on why you are eligible to file on paper:

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If you are filing on paper because you have been granted a continuing hardship
exemption, submit one manually signed Form ADV and one copy to: IARD Document
Processing, FINRA, P.O. Box 9495, Gaithersburg, MD 20898-9495.
If you complete Form ADV on paper and submit it to FINRA but you do not have a
continuing hardship exemption, the submission will be returned to you.

•

19.

If you are filing on paper because a state in which you are registered or in which you are
applying for registration allows you to submit paper instead of electronic filings, submit
one manually signed Form ADV and one copy to the appropriate state securities
authorities.
Who is required to file Form ADV-NR?

Every non-resident general partner and managing agent of all SEC-registered advisers and
exempt reporting advisers, whether or not the adviser is resident in the United States, must
file Form ADV-NR in connection with the adviser’s initial application or report. A general
partner or managing agent of an SEC-registered adviser or exempt reporting adviser who
becomes a non-resident after the adviser’s initial application or report has been submitted
must file Form ADV-NR within 30 days. Form ADV-NR must be filed on paper (it cannot
be filed electronically).
Submit Form ADV-NR to the SEC at the following address:
Securities and Exchange Commission, 100 F Street, NE, Washington, DC 20549;
Attn: Registrations Branch.
Failure to file Form ADV-NR promptly may delay SEC consideration of your initial
application.

Federal Information Law and Requirements
Sections 203 and 204 of the Advisers Act [15 U.S.C. §§ 80b-3 and 80b-4] authorize the SEC to
collect the information required by Form ADV. The SEC collects the information for regulatory
purposes, such as deciding whether to grant registration. Filing Form ADV is mandatory for
advisers who are required to register with the SEC and for exempt reporting advisers. The SEC
maintains the information submitted on this form and makes it publicly available. The SEC may
return forms that do not include required information. Intentional misstatements or omissions
constitute federal criminal violations under 18 U.S.C. § 1001 and 15 U.S.C. § 80b-17.

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SEC’s Collection of Information
An agency may not conduct or sponsor, and a person is not required to respond to, a collection of
information unless it displays a currently valid control number. The Advisers Act authorizes the
SEC to collect the information on Form ADV from investment advisers. See 15 U.S.C. §§ 80b-3
and 80b-4. Filing the form is mandatory.
The form enables the SEC to register investment advisers and to obtain information from and
about exempt reporting advisers. Every applicant for registration with the SEC as an adviser,
and every exempt reporting adviser, must file the form. See 17 C.F.R. § 275.203-1 and 204-4.
By accepting a form, however, the SEC does not make a finding that it has been completed or
submitted correctly. The form is filed annually by every adviser, no later than 90 days after the
end of its fiscal year, to amend its registration or its report. It is also filed promptly during the
year to reflect material changes. See 17 C.F.R. § 275.204-1. The SEC maintains the information
on the form and makes it publicly available through the IARD.
Anyone may send the SEC comments on the accuracy of the burden estimate on page 1 of the
form, as well as suggestions for reducing the burden. The Office of Management and Budget has
reviewed this collection of information under 44 U.S.C. § 3507.
The information contained in the form is part of a system of records subject to the Privacy Act of
1974, as amended. The SEC has published in the Federal Register the Privacy Act System of
Records Notice for these records.