Alert March 22, 2011

SEC Staff Provides Responses to Questions About Part 2 of Form ADV

The staff of the SEC’s Division of Investment Management has posted on the SEC website responses to questions about Form ADV Part 2A (brochure) and Part 2B (brochure supplement).  The questions regarding the brochure cover topics such as (1) identification of material changes, (2) required headings, (3) risk disclosures for investment strategies/methods of analysis and (4) brochure delivery to fund investors.  The questions regarding the brochure supplement cover topics such as (a) delivery obligations when a supervised person provides advisory services on a temporary basis or following a predecessor’s resignation or termination, (b) delivery obligations when investment recommendations are computer-generated, (c) explanation of professional designations and (d) identification of supervising persons.