Updated as of March 18, 2011.

Need help implementing an ongoing and comprehensive compliance program? Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. Form ADV is used by investment advisers to register with the Securities and Exchange Commission (SEC) and  state securities authorities. Suite 1326 The determination to use a third-party compliance services provider is an important decision and should not be based solely upon advertisements or self-proclaimed expertise. For your reference, the following has been excerpted directly from the SEC’s Form ADV instructions (https://www.sec.gov/about/forms/formadv-part2.pdf). From time to time, an investment of a Retirement Plan We service or platform You utilize makes payments to Us in exchange for certain services we provide to them. Form ADV Part 2 (IARD System Instructions) Under Securities and Exchange Commission (SEC) and similar state rules, investment adviser firms are required to provide clients and prospective clients with a brochure disclosing information about the firm. The items require narrative responses. An investment adviser firm only needs to deliver once per year no later than 120 days after the investment adviser firm’s fiscal year-end either (1) the current Form ADV Part 2A brochure with material changes made within the prior one-year period or (2) a summary of material changes made within the prior one-year period with an offer to provide a complete copy of Form ADV Part 2A brochure upon request. Out of these, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. Form ADV Part 2 Access Betterment’s Form ADV Part 2A. Necessary cookies are absolutely essential for the website to function properly.

You must give a firm brochure to each client before or at the time you enter into an advisory agreement with that client. As explained above, this standardized disclosure provides greater detail about our firm and the types of services we provide, along with other regulatory information you may wish to review.

endstream endobj startxref The staff of the Division of Investment Management has prepared the following responses to questions about Part 2 of Form ADV, under the Investment Advisers Act of 1940 and expects to update from time to time our responses to additional questions. There are two exceptions to the annual offer of the Form ADV Part 2A for existing investment advisory clients. ), 262 0 obj <>/Filter/FlateDecode/ID[<2A0CFF667EE6DC42848092345C441C25>]/Index[253 21]/Info 252 0 R/Length 60/Prev 248942/Root 254 0 R/Size 274/Type/XRef/W[1 2 1]>>stream 605 0 obj <>/Filter/FlateDecode/ID[<781AADE634EB7D41A00E475A1A6EA549><4D06715DB0226640B190089B584CE184>]/Index[587 27]/Info 586 0 R/Length 93/Prev 271198/Root 588 0 R/Size 614/Type/XRef/W[1 3 1]>>stream These brochures are also available to the public as well. However, if the change impacts a particular set of investment advisory clients, the investment adviser firm needs to inform those investment advisory clients of the change. L��a��� r=�L�V��H�O�f`bd`��C�����/� �C/ All potential clients are urged to make their own independent investigation and evaluation of RCC. Form ADV Part 2 – The New Disclosure Brochure for Investment Advisers ALI-ABA Investment Adviser Regulation New York, New York Jennifer L. Klass Morgan, Lewis & Bockius LLP 101 Park Avenue New York, New York 10178 212.309.7105 jklass@morganlewis.com Steven W. Stone Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, N.W. These cookies will be stored in your browser only with your consent. 0 Form ADV Part 2 acts as a disclosure document for clients and prospective clients. ��)`&XּNx�x�Q�-m���� �d�q��09����ʚyXK��B���q]X�!.��*P�=M.B��#�C�@)30��vʛ~v%H�۬*����ċ� �,� {{GcE�ysE{�``.CE�8�p�`�h��� q��':0i��(���. For more information, please visit our Disclosures webpage. These cookies do not store any personal information.

�O�B'ײ� R�.T,�����a;�\p�¿) ����X3�8F+�E�F��F�F4 ��8/����h�0���v��9�Iq�B��jf�7.t�d�z�N�p13Q��䛔�!�:@��̸ $$n40p40h40t00pt � ��F0��$����d�9@Q�4P�hwi10��i��EA�f��1&0�1�cx�����Q���#�����o� �~�FREd&g�{�l�,�r� ��pQ�8�K5Ѯ� �����y$ ���2/0�ُgpK�(5�,IxUv7,_�6��6劶܌�p� ɵ��"�!o���"-�ޢ� ��lک�. Form ADV is a form that investment advisers have to file with the SEC.


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