Annual Letter: 2019

This is our annual letter briefly reviewing various issues that our investment adviser clients should consider over the next few weeks. We will be pleased to respond to questions, assist you in preparing needed forms and otherwise assist you in satisfying any of the requirements discussed in this letter. Please contact John Broadhurst, Carolyn Reiser, Jahan Raissi, Neil Koren, Jim Frolik, Christina Hamilton, David Suozzi or Joan Grant.

Federally Registered Investment Advisers

1. Annual Updating Amendment to Form ADV. If your firm is SEC-registered, it must amend its Form ADV each year on the IARD within 90 days after the end of its fiscal year.  For an adviser whose fiscal year ended December 31, 2018, the deadline is March 31, 2019, which is a Sunday. The IARD is open from 10 a.m. to 6 p.m. ET that day, but the last business day before this deadline is March 29, 2019. This annual amendment must update your firm’s responses to all items of Parts 1 and 2 of Form ADV.

When you amend Part 1, the IARD will prompt you to indicate the type of amendment.  You should select “annual updating amendment,” and indicate that the amendment is for 2018.  Unlike Part 1, Part 2A is not an online form. Instead, you must upload Part 2A on the IARD as a separate document in text-searchable PDF format. An SEC-registered investment adviser is not required to file Part 2B or any amendments to it, but must keep its updated Part 2B in its records.

The IARD filing fees for an SEC-registered adviser’s annual updating amendment are (a) $40 if the adviser’s RAUM is below $25,000,000, (b) $150 if RAUM is between $25,000,000 and $100,000,000 and (c) $225 if RAUM is over $100,000,000. You must fund your IARD account with the appropriate amount before you submit the amendment. Information about funding your firm’s IARD account is at

To determine your firm’s RAUM, include the securities portfolios for which your firm provides continuous and regular supervisory or management services as of the date you file the Form ADV amendment. Your firm’s RAUM should be based on the current market value of those assets as of a date within 90 days before the date you file the Form ADV amendment. You should determine market value using the same method you use to report account values to clients or calculate your investment advisory fees.

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