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Connecticut Adopts New Form ADV Part 2 for IAs in 2011

By Jim Hamilton

Investment adviser applicants filing an initial Form ADV, Uniform Application
for Investment Adviser Registration, may between October 12, 2010 and January 1, 2011 submit electronically through the IARD or file in paper format directly with the Securities and Business Investments Division of the Connecticut Department of Banking either current Part II or new Part 2 of Form ADV. Beginning January 1, 2010 investment adviser applicants must electronically file new Part 2 with the IARD as part of their Form ADV application.

Connecticut-registered investment advisers between October 12, 2010 and January 1, 2011 may submit Form ADV amendments electronically through the IARD or in paper format directly to the Securities and Business Investments Division using either current Part II or new Part 2 or Form ADV. Investment advisers registered in Connecticut on or before December 31, 2010 should update their information on current Part II by filing new Part 2 between January 1 and June 1 of 2011 (no later than June 1, 2011). All Connecticut-registered investment advisers starting January 1, 2011 must electronically file with the IARD any Form ADV amendments using new Part 2. CAUTION: Connecticut does not require investment advisers to file an annual updating amendment but mandates that Form ADV be amended to reflect material information changes [see Rule 36b-31-14e(a)] and specifies annual delivery of the brochure or an offer to deliver it to their clients [see Rule 36b-31-5c(d)(1)].

PDF format required. Form ADV Part 2 must be electronically filed with the IARD as a searchable text, portable document format (PDF) file.

Note on federal covered investment advisers. Federal covered investment advisers filing a notice in Connecticut need only submit Part 2 of Form ADV if requested by the Securities and Business Investments Division, according to the instructions for filing new Part 2, as stated by Cynthia Antanaitis, the Assistant Director for the Division.

Please see http://www.ct.gov/dob for more information.

Full post as published by Jim Hamilton's World of Securities Regulation on October 27, 2010 (boomark / email).