Compliance Reminder: Annual Obligation to Update Form ADV

February 24, 2016

As a reminder, if you are an SEC-registered investment adviser or an exempt reporting adviser, you are required to update your Form ADV within 90 days of your fiscal year-end.

If you are an SEC-registered investment adviser, you are also required to perform an annual review of your compliance policies and procedures.

See our compliance website at for recent updates to Seward & Kissel’s Model Compliance Manual, Code of Ethics and guides to Form ADV Part 1 and 2.


If you have any questions regarding the matters covered in this e-mail, please contact any of the partners and counsel listed below or your primary attorney in Seward & Kissel’s Investment Management Group.