On March 25, 2020, the SEC announced the extension of filing and delivery deadlines for investment advisers if impacted by the coronavirus. The Commission also eased disclosure requirements for advisers relying on this extension.
The Orders dated March 25, 2020 supersede and extend the filing periods covered by the Original Orders dated March 13, 2020. Among other conditions, entities must notify the Division staff and/or investors, as applicable, of the intent to rely on the relief, but generally no longer need to describe why they are relying on the order or estimate a date by which the required action will occur.
Investment advisers relying on this Order with respect to the filing of Form ADV or delivery of its brochure, summary of material changes, or brochure supplement required by Rule 204-3(b)(2) or (b)(4), must promptly notify the Commission staff via email at IARDLive@sec. gov and disclose on its public website that it is relying on this Order. Any investment adviser relying on this order with respect to filing Form PF required by Rule 204(b)-1 must promptly notify the Commission staff via email at FormPF@sec. gov stating that it is relying on this Order.
The Order would extend the following obligations for which the original due date is on or after the date of the original Order (March 13, 2020) but on or prior to June 30, 2020. Advisers must file as soon as practicable, but not later than 45 days after the original due date for filing or delivery, as applicable.
- Amendments to Form ADV and reports on Form ADV Part 1A;
- Amended brochures, brochure supplements or summary of material changes to clients and;
- Form PF filing requirements