On May 20, 2015, the SEC issued a release proposing to expand Form ADV Part 1A to gather more detailed information about SMAs, as well as other aspects of an adviser’s business. The proposal would greatly impact the disclosure requirements applicable to MMI members, as the definition of SMA under the proposal is broadly defined and would include any account that is not a pooled investment vehicle.
MMI member firms worked in collaboration with MMI's retained counsel, Morgan, Lewis & Bockius, to develop comments on the proposed amendments to Form ADV and certain rules under the Investment Advisers Act of 1940. As expressed in MMI's comment letter, MMI is supportive of the SEC’s efforts to obtain additional information about investment advisers to SMAs, however we are concerned about some uncertainties in the proposed rule as well as the extent of some proposed reporting requirements. The comment letter, which was submitted to the SEC on August 11, 2015, is available here to review (Members only PDF).