Compliance and Regulatory Alerts - 03-26-20

Update: SEC Amends ADV Filing and Delivery Deadline Extensions due to COVID-19

The SEC’s IAA Release No. 5469 on Wednesday, March 25, 2020 amends its IAA Release No. 5463 and now allows for extending the filing (March 30) and delivery (April 30) deadline dates of the Form ADV amendment to June 30, 2020 due to COVID-19 and its consequences. The SEC has also amended the notice requirements, eliminating the need to describe why the requirement cannot be met and when you expect to file. 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 the original Order.
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. We are relying on the SEC IAA Release No. 5463 of Friday, March 13, 2020 for this extension."

Please contact Bates Compliance 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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