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Asher Bearman

It’s getting down to the wire for fund managers who will be filing their first Form ADV this year with the Securities and Exchange Commission (SEC).  The SEC has advised first time filers that it can take up to 45 days for initial applications to be approved.  As a result, advisers that need to report information about themselves and their funds by March 30, 2012 should plan to file their completed Form ADV no later than February 14, 2012 to ensure timeliness.  Fund managers who are not registering do not need to file in advance, but, as with everything, waiting until the last minute is not recommended.

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The Form ADV has to be filed electronically using the SEC’s Investment Adviser Registration Depository (IARD).  For new filers, that means that the first step in the process will be to register for the SEC’s IARD electronic filing system:, using the SEC Entitlement Packet. This will get you a login so that you can make your first Form ADV filing. 

Once you are in the IARD system, you can then proceed to file the Form ADV. Exempt fund advisers (primariy, advisers who manage solely VC funds or managers of less than $150M AUM) only need to file certain portions of the first part of Form ADV (Part 1A), per our prior summary:

Exempt Adviser Reporting Requirements

The instructions to the Form ADV are also detailed and should be helpful.