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News September 20, 2004 Issue

2005: The Year of Form ADV Part 2

Look to see final Form ADV Part 2 adopted before spring 2005, SEC associate director Robert Plaze told IM Insight, although he warned that "there could be slippage."

Plaze said that the IARD system will be ready to accept filings "sometime towards the middle of 2005." He said that the SEC will provide a transition period. "2005 will be the transition to the narrative Part 2," he predicted. "We thought we’d let people get through the compliance program this year."

Here’s how the new Part 2 filing process will work: advisers will prepare their Part 2 brochure either on their own word processing software or perhaps using a desktop publishing firm to make it look snazzy. Once the brochure is complete, advisers will have to convert their brochure to an Adobe Acrobat™ pdf file. Plaze said that the Adobe software will be provided for advisers that don’t have it. Advisers will then go onto IARD and upload the pdf’ed brochure from their hard drive onto the IARD system. "You will attach your pdf file to the filing just like you attach a Word™ document," said Plaze. He said it would involve "just a few keystrokes." The benefit to uploading a pdf is that all charts, graphs, and pictures will be available on the pdf, he added.