The SEC has extended by 4 months the delivery date for the new adviser Brochure Supplement required by Part 2B of the new form ADV.  The Brochure Supplement contains information about the advisory personnel that provide services to each client.  Advisers with fiscal years ending on December 31 have until July 31 to deliver Brochure Supplements to new clients and until September 30 to deliver the Brochure Supplement to existing clients.  New advisers have tighter delivery requirements depending on their filing dates.  For state registered advisers, the SEC advises consultation with the applicable state regulator to determine whether such state will similarly extend the delivery date.  The extended compliance date does not affect the delivery of Part 2A, which must be delivered to existing clients by May 30 for advisers with a December 31 fiscal year end.  The new ADV must still be filed with the SEC by March 31. 

OUR TAKE: This extension helps large advisers who need to customize Brochure Supplements for hundreds/thousands of clients.  Nevertheless, the March 31 deadline remains for filing of the completely revised ADV.

 http://www.sec.gov/rules/final/2010/ia-3129.pdf