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.


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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