Form ADV disclosures
Technology and AI firms registered as investment advisers face direct Form ADV disclosure obligations that the U.S. Securities and Exchange Commission has sharpened through its 2023 amendments to Part 1A and Part 2A, requiring advisers to itemize algorithmic conflicts, data monetization practices, and material relationships with affiliated technology vendors. The SEC's Division of Examinations has flagged AI-related disclosure gaps as a 2024 examination priority, which means compliance teams at tech-sector RIAs are actively auditing their brochure language against actual model usage before the next exam cycle.
Watch
- SEC Part 2A Item 8 scrutiny of AI-driven portfolio management conflict disclosures
- 2024 SEC Examination Priorities memo: AI and algorithmic strategy disclosure gaps named explicitly
- Adviser obligations when a technology affiliate also supplies the firm's data infrastructure
- Form ADV annual amendment deadline: 90 days post-fiscal-year-end for calendar-year filers
- FTC enforcement actions on AI data practices creating parallel disclosure pressure for dual-registered entities
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