Seward & Kissel briefing: ESG considerations for Form ADV Annual Amend
Seward & Kissel has published a client memorandum on ESG considerations for ‘Brochures’ disclosures in Part 2A of Form ADV.
On 12 March 2021, Seward & Kissel, our alliance firm for hedge fund and asset management work, published a client memorandum.
The memorandum recommends that SEC-registered investment advisers which have a FYE of 31 December (and so must submit an annual amendment to their Form ADV by March 31, 2021) consider whether their Form ADV fully and accurately discloses how ESG impacts their businesses and their provision of advisory services. This is especially important where they have adopted ESG policies and procedures, have integrated ESG into their investment process, and/or manage impact investing and/or ESG-focused strategies.
Seward & Kissel recommend that advisers consider addressing ESG matters in their Form ADV Part 2A (Brochure) disclosures, specifically in:
- Item 5 (Expenses);
- Item 8 (Methods of Analysis, Investment Strategies and Risk of Loss); and
- Item 17 (Proxy Voting).
For more information, please contact Iain Cullen, Lucian Firth, Richard Perry or Devarshi Saksena or speak to an attorney at Seward & Kissel.
