In this SRZ Insights video, partner Brian Daly discusses the potential impact of Form ADV amendments on U.K. investment managers. He addresses key aspects of the major changes — including how the biggest change impacts the use of the client- and investor-friendly umbrella registration by non-U.S. managers.

SRZ on Aug. 11, 2015 submitted comments to the U.S. Securities and Exchange Commission on the agency’s proposed amendments to Form ADV and the corresponding rules under the Investment Advisers Act. SRZ’s comment letter addresses confidentiality concerns about the proposal’s obligation for advisers to make detailed disclosure of proprietary information regarding separately managed accounts. The firm also makes suggestions regarding the SEC’s proposal to incorporate “umbrella registration” into Form ADV, particularly for foreign advisers.

SRZ’s comment letter was submitted by the firm’s regulatory & compliance practice, which is carefully following the SEC’s development of rules affecting advisers to private funds and SMAs.

Click here to read the comment letter.


In the proposing release for the Form ADV amendments, the SEC is asking advisers to provide substantial amounts of information on their managed accounts. The new information gathered on Form ADV is meant to be a complement to Form PF data that is already collected by the U.S. government. The questions differ slightly and managers should confirm that they would be in a position, technically and under their various management agreements, to complete this new section of the Form ADV. In addition, managers should note that the proposed rule does not treat these responses confidentially, which contrasts with the treatment of Form PF data.

Click here to read this article, in which SRZ partner Brian T. Daly discusses how fund managers can prepare for the new SEC Form ADV disclosures.