Have You Named Your CCO Yet?
The SEC last week began e-mailing advisers that have not yet named a CCO on Form ADV Schedule A.
For firms with a December 31 fiscal year end, the CCO should have been added to the list of direct owners and executive officers on Schedule A of Form ADV in the annual updating amendment filed the end of March (the amendment required to be filed within 90 days of the end of a firmís fiscal year).
The SECís inquiry may have been prompted by a recent report issued by the Investment Adviser Association and National Regulatory Services. The report found that as of April 5, 2005, only 54.6 percent of SEC-registered advisers had named a CCO on Form ADV. The report also found that an additional 6.2 percent of firms identified an individual with "compliance" in his or her title.