ComplianceAlert
ComplianceAlert

New SEC No-Action Letter on Brochure Delivery Impacts Client Disclosures

The SEC’s Division of Investment Management issued a new no-action letter regarding when advisers must deliver Form ADV Part 2 to clients. The letter is specific to advisers that manage assets via sub-advisory relationships. The letter, issued to Goldman, Sachs & Co. (“GS&Co.”), allows the primary adviser, in this case GS&Co., to receive the subadviser’s…

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