The Foley Adviser

SEC to Provide Temporary Relief to Form ADV and PF Deadlines for Advisers Affected By COVID-19

March 16, 2020

All federally registered investment advisers and exempt reporting advisers are advised that in response to the disruptions resulting from COVID-19, the SEC has provided relief to allow affected advisers to extend the due date for filing of annual amendments to Form ADV and filing of Form PF. The relief is available with respect to filings that are otherwise due between March 13, 2020 and April 30, 2020, and to the extent that the adviser is unable to meet the normal course due date due to the effects of COVID-19. An adviser who seeks to claim this relief with respect to Form ADV must file notice with the SEC and publish notice on its web site (or other means to inform its clients and investors if the adviser does not have a publicly accessible web site) that it is relying on the relief, including a brief description of the reasons why it is unable to meet the normal course deadline, and an estimated date when it expects to make the applicable filing. Advisers claiming relief for a Form PF filing must provide notice to the SEC that they are claiming the relief.

A copy of the release is available here.

Foley Hoag has formed a firm-wide, multi-disciplinary task force dedicated to client matters related to the novel coronavirus (COVID-19). For more guidance on your COVID-19 issues, visit our Resource Page or contact your Foley Hoag attorney.