Annual Form ADV Reminder

This is a friendly reminder for you to file your annual Form ADV update and to review your firm's registration as an investment adviser. The U.S. Securities and Exchange Commission ("SEC"), and each State's securities division, requires all registered investment advisers to annually renew their registration. The 2011 renewal consists of, but is not limited to, a renewal fee and revisions to the Form ADV to reflect current and accurate information about your firm's business. We will send you a preliminary renewal statement along with the associated renewal fees by the end of this month.

Please note that the annual renewal fee varies based on your assets under management and your principal place of business. Once the renewal statement has been filed, the annual amendment to the firm's Form ADV will be due, at the latest, 90 days after December 31, 2010.

Please advise us by November 16, 2010 if you intend to withdraw your registration as an investment adviser for 2011 or if you are conducting the renewal process independently.

You should be aware that under Title IV of the Dodd-Frank Wall Street Reform and Consumer Protection Act, some unregistered investment advisers may be required to register with the SEC or their respective State(s). Moreover, some registered investment advisers may be required to de-register or transition from SEC to State registration, or vice versa.

Also, the SEC has made significant changes to the Form ADV Part II and now requires a narrative disclosure document to be submitted in place of the former "check-the-box format." Any previously filed ADV Part II will need to be updated accordingly.

If you have any questions regarding the renewal process, please feel free to contact Daniel G. Viola at 212.573.8038 or dviola@sglawyers.com.

 

Cheryl Spratt