State of Connecticut Department of Banking

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PART 2 (OF FORM ADV) POINTERS


1. Web CRD/IARD Allows You to File Part 2 Electronically
  
Since 2007, the online Investment Adviser Registration Depository (IARD) has been able to accept the filing of Form ADV Part 2 electronically.
 
2. PDF Format Required
  
Form ADV Part 2 must be submitted to IARD as a searchable text, portable document format (PDF) file.  For guidance on how to use this functionality, see the Form ADV Part 2 (IARD System Instructions) available on the IARD website.
    
3. Plain English Disclosure and Part 2 of Form ADV
    
On July 28, 2010 the Securities and Exchange Commission released a revised Form ADV [SEC Release No. IA-3060; File No. S7-10-00]. The release amended Part 2 of Form ADV (also called the “brochure”). To provide more meaningful disclosure to advisory clients, the amendment changed the format of Part 2 from a check-the-box form to a narrative brochure written in plain English.  The brochure must be filed electronically through the IARD System.
   
Part 2 has three parts:  1) Part 2A (the Firm Brochure); 2) Part 2A Appendix 1 (Wrap Fee Program Brochure); and 3) Part 2B (the Brochure Supplement, providing information on investment advisory personnel). Each investment adviser must complete Part 2A (the Firm Brochure) and Part 2B (the Brochure Supplement).  Only investment advisers who provide wrap fee programs are required to submit Appendix 1 to Part 2A (the Wrap Fee Program Brochure).
    
4. Amendments to Part 2 of Form ADV; Brochure Delivery to Clients
       
While Connecticut does not require that advisers file an annual updating amendment, Section 36b-31-14e(a) of the Regulations under the Connecticut Uniform Securities Act requires that investment advisers amend their Form ADV when it becomes materially inaccurate or incomplete.  In addition, Section 36b-31-5c(d)(1) of the Regulations requires advisers to deliver or offer to deliver the brochure to their clients each year.
    
5. Resources
    
A free editable PDF version of the current Form ADV Part II is available on the website of the North American Securities Administrators Association, Inc. (NASAA) under Industry Resources (Uniform Forms).