Annual updating amendment to form adv

No supplement is required for a supervised person who has no direct client contact and has discretionary authority over a client’s assets only as part of a team.In addition, if discretionary advice is provided by a team comprised of more than five supervised persons, brochure supplements need only be provided for the five supervised persons with the most significant responsibility for the day-to-day discretionary advice provided to the client.You must deliver to clients any update to the supplement that amends information in response to Item 3 of Part 2B (disciplinary information).Such an amendment can be in the form of a “sticker” that identifies the information that has become inaccurate and provides the new information and the date of the sticker.

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Important Information The information contained in this Frequently Asked Questions is only a summary and is not intended to be a comprehensive analysis of the rules and regulations applicable to registered investment advisers.

Among other things, a brochure supplement contains information about the educational background, business experience and disciplinary history (if any) of the supervised persons who provide advisory services to the client.

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