Recognizing the impact that COVID-19 has on administration and compliance, the Securities and Exchange Commission said Wednesday that it is further extending filing dates for certain regulatory requirements, including Form ADV.
The original order extended the date to April 30, 2020. The extension applies to filing obligations “for which the original due date is on or after the date of the original order, but on or before June 30, 2020.”
Filing or delivery would still need to be made as soon as practicable but no later than 45 days after the original due date, according to the commission.
[See Full SEC Filing Extension Announcement Here]
The language in the most recent announcement reads as follows:
- Registered investment advisers and exempt reporting advisers affected by Coronavirus to file an amendment to Form ADV or file reports on Form ADV Part 1A, respectively:
- Registered investment advisers affected by Coronavirus from requirements to deliver amended brochures, brochure supplements or summary of material changes to clients where the disclosures are not able to be timely delivered because of circumstances related to Coronavirus; and
- Private fund advisers affected by Coronavirus from Form PF filing requirements.
“Health and safety continue to be our first priority,” said SEC Chairman Jay Clayton said in a statement. “These actions provide temporary, targeted relief to issuers, investment funds and investment advisers affected by COVID-19. At the same time, we encourage public companies to provide current and forward-looking information to their investors and, in these uncertain times, companies are reminded that they can take steps to avail themselves of the safe harbor in Section 21E of the Exchange Act for forward-looking statements.”
Previous order extended
Today’s orders supersede and extend the filing periods covered by the commission’s original orders of March 13.
“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,” the announcement added.
With more than 20 years serving financial markets, John Sullivan is the former editor-in-chief of Investment Advisor magazine and retirement editor of ThinkAdvisor.com. Sullivan is also the former editor of Boomer Market Advisor and Bank Advisor magazines, and has a background in the insurance and investment industries in addition to his journalism roots.
