SEC registered investment advisers receiving Federal loans under the Paycheck Protection Program (PPP), should consider whether their situation requires an ADV, Part 2 disclosure. FrontLine’s Founder and President, Amy Lynch, comments that advisory firms have to make an assessment of their own unique financial condition to determine if disclosure is necessary. Ms. Lynch advises that disclosure would be considered if other factors are involved outside of the virus impact, and the loan is propping up the advisory firm for other reasons not directly related to the current crisis. See InvestmentNews, “Some seek SEC guidance on whether RIAs must disclose COVID-19 loans“
