SEC Is Not Extending the Deadlines for RIAs to File/Deliver Form ADV Part 3 Due to COVID-19

April 03, 2020

In response to numerous inquiries and requests for an extension of the deadlines facing SEC registered investment advisers related to filing and/or delivering the Form ADV Part 3/Client Relationship Summary (“CRS”), the U.S. Securities  and Exchange Commission (“SEC”) issued a Public Statement on April 2, 2020 indicating that the SEC is not extending the filing and delivery deadline for the Form ADV Part 3/CRS.

Jay Clayton, the Chairman of the SEC, urged investment adviser firms to “continue to make good faith efforts around operational matters to ensure compliance by June 30, 2020, including devoting resources as necessary and available in light of the circumstances. “

The SEC Chairman noted that “[t]o the extent that a[n investment adviser] firm is unable to make certain filings or meet other requirements because of disruptions caused by COVID-19, including as a result of efforts to comply with national, state or local health and safety directives and guidance, the [investment adviser] firm should engage with [the SEC].  I expect that the Commission and the staff will take the [investment adviser] firm-specific effects of such unforeseen circumstances (and related operational constraints and resource needs) into account in our examination and enforcement efforts.”

For the full text of the SEC’s Public Statement entitled “Investors Remain Front of Mind at the SEC: Approach to Allocation of Resources, Oversight and Rulemaking; Implementation of Regulation Best Interest and Form CRS”, please visit https://www.sec.gov/news/public-statement/statement-clayton-investors-rbi-form-crs .

Form ADV Part 3 FAQs

To help investment advisers understand what will be required by the Form CRS Relationship Summary/ADV Part 3, RIA Compliance Consultants created a webpage, Form ADV Part 3 FAQs. The page features 25 questions with detailed answers about the requirements for the Form CRS Relationship Summary/ADV Part 3. Because the SEC is not extending the deadline for the ADV Part 3, we encourage all SEC registered investment advisers to view these FAQs.

To further assist investment advisers you can watch our recorded webinar “How the SEC’s Recent Approval of Form CRS/Form ADV Part 3 Affects Investment Advisers.” We made these resources freely available to help investment advisers understand the importance of the of the Form ADV Part 3/CRS.  We also invite you to read and continue to monitor our blog page where we will continue to provide investment advisers information about the Form CRS Relationship Summary/ADV Part 3. Click here to read our initial post providing investment advisers a brief summary about the new requirements for the Form CRS Relationship Summary/Form ADV Part 3.

Free Upcoming Webinar – Preparing Form ADV Part 3

On April 22, 2020, Bryan Hill will be discussing how to prepare the Form ADV Part 3 for investment adviser firms registered with the SEC. Bryan will also talk about the SEC’s deadline for the ADV Part 3. Click the following link to register for this free webinar https://zoom.us/webinar/register/WN_CsHILWJHRQK8YZnrutpdow. 

Contact Us

If your investment adviser firm is an existing client of RIA Compliance Consultants and has questions about the Form CRS Relationship Summary/ADV Part 3, we encourage you to speak with your compliance consultant or, if you are not a an existing client, of RIA Compliance Consultants click here to set up an introductory call with one of our Senior Compliance Consultants.

Posted by Grant Parr
Labels: ADV Part 3, COVID-19, SEC