Compliance and Regulatory Alerts - 03-16-20

SEC Extends Form ADV Filing and Delivery Deadlines due to COVID-19

The SEC’s IAA Release No. 5463 on Friday, March 13 allows for extending the filing (March 30) and delivery (April 30) deadline dates of the Form ADV amendment by 45 days due to COVID-19 and its consequences. However, this is not an automatic extension. If you cannot meet the filing deadlines, you MUST do the following:

Email IARDLive@SEC.gov AND post on your website (or, if you do not have a website, notify your clients/investors directly):

  • That your firm is relying on this Order,
  • A brief description of why you are unable to file or deliver on a timely basis,
  • The estimated date by which you expect to file/deliver the filing.

Example: 

  • “Our firm, ABC Inc., CRD# xxxx, SEC# 801-yyyy, will not be filing its Form ADV amendment by March 30 or delivering it by April 30 due to the COVID-19 virus because of the following. We are relying on the SEC IAA Release No. 5463 of Friday, March 13, 2020 for this extension. (Pick one of the below, or change the language to fit your circumstance…)
  • Our office is working with a skeleton staff which is unable to gather required information, or
    • Critical staff for gathering information for the filing are focused on the market and client calls, or
    • We are experiencing extensive staff illness or staff are caring for ill family members and are unable to work, or
    • We are unable to receive needed information for an accurate filing from third parties within the initial filing date.
  • We expect to be able to file accurate information by (date no later than May 14, 2020) and to deliver required information to our clients by (date no later than June 13, 2020)."

Please contact us to assist your firm with Form ADV or to discuss your discrete and ongoing compliance needs:

Linda Shirkey, Managing Director

lshirkey@batesgroup.com - (281) 298-7015

 

Rory O’Connor, Director

roconnor@batesgroup.com - (860) 671-7270


About Bates Compliance

The Bates Compliance team of senior compliance staff and former regulators bring tailored regulatory compliance services, guidance, and expertise to financial services clients on an as-needed or ongoing basis to meet the evolving requirements and practices of today’s global financial services industry. Bates Compliance provides a wide range of support to financial institutions of all sizes, structures, and business models, and works with its clients to review, test, and bolster their compliance programs. Bates Compliance provides and implements solutions based on regulatory requirements and industry-accepted best practices designed to supplement and enhance compliance and supervisory systems and to remediate the results of regulatory and internal audit findings.

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