With all the details finalized, the "Big Switch" is in full swing. For the estimated 3,200 RIAs that will be impacted by these new rules, here are some important dates to keep in mind.
January 1, 2012: If you are currently registered or pending with the SEC, you must amend your ADV no later than March 30, 2012. New advisors filing in 2012 must have $100 million or more within 120 days
January 1, 2012 to March 30, 2012: Existing mid-size SEC advisors may select any date in this range for calculation of their "regulatory assets".
March 30, 2012: Deadline for ADV amendment for all advisors (SEC, State or transitioning)
June 28, 2012: Deadline for withdrawal from SEC registration.
Needless to say, this transition can be complicated and will impact a significant number of RIAs. If you have any questions, feel free to drop us a note at firstname.lastname@example.org.