Update to Investment Adviser Switch to State Regulation

The Securities and Exchange Commission has extended the date for investment advisers with assets under management of between $25 million and $100 million to switch from SEC registration to state registration.  Advisers will be required to amend their Form ADV between January 1, 2012 and March 31, 2012 to report their current assets under management.  Advisers that are no longer eligible for SEC registration at that time will be required to file a Form ADV-W with the SEC no later than June 28, 2012.  An additional change is that there will now be a "buffer" for maintaining SEC registration for firms with assets under management of between $90 - $110 million.  We are in process of updating the "Presentation for Investment Advisers Switching to State Regulation" that was previously posted here, which will provide more complete information

July 29, 2011