SEC Calls for Form PF Data about SMAs and More Fund Holdings Reporting
The SEC has proposed amendments to Form ADV that would require information about separately managed accounts similar to the information currently required on Form PF for private funds. If adopted, a registered adviser would report the percentage of SMAs invested in 10 asset categories, significant information concerning the use of borrowings and derivatives, and the SMA custodians. The proposal also requires more information about an adviser’s branch office operations and use of social media. The SEC also proposed changes to registered fund disclosure including monthly portfolio reporting and a new form to replace Form N-SAR.
OUR TAKE: If adopted (as expected), RIAs will need to engage in significant data collection and drafting to create their new ADVs. It will be similar to the effort undertaken when the SEC overhauled Form ADV in 2011 and will follow the same process as Form PF.