The SEC announced on March 25, 2020 additional regulatory relief for investment advisers impacted by the Coronavirus. The SEC extended relief from May 15 until June 30, 2020 for filing an amendment to Form ADV Part 1A and the Brochure (ADV Part 2A) and related delivery obligations. https://www.sec.gov/rules/other/2020/ia-5469.pdf. The annual amendments for ADV are normally due March 30, 2020 for most firms. The SEC originally extended these deadlines in an order issued March 13, 2020. In the new order, the SEC also relaxed the requirements for qualifying for the extension. Under the new rule, the adviser no longer has to give an estimated date of compliance or to explain the circumstances of the delay.
To qualify for the relief the adviser must (1) be unable to meet a deadline due to circumstances related to the Coronavirus; (2) notify the SEC by email that it is relying on this order, and (3) post the same information on the adviser’s web site. The relief applies to filings due from March 13 through June 30.
This relief only applied to federally registered investment advisers. No word as of yet on whether the States of Louisiana, Texas or Mississippi will grant similar relief. Please feel free to contact me if you would like additional information.
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