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A Better Partnership

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Mar 2011
22
March 22, 2011

Part 2A Deadline Extended In Michigan

There is good news for all investment advisers registered with the State of Michigan. At an OFIR sponsored Investment Adviser Seminar held Monday in Troy, Linda Cena, the director of securities for Michigan and the head of the North American State Securities Administrators Association advisor section, said that in Michigan, no action will be taken against advisors making a good-faith effort to file Part 2A of their Form ADV until 30 days after the March 31 deadline.

This effectively extends the Part 2A deadline until April 30. Keep in mind that if you have material changes to Part 1 of your Form ADV, your amended Part 1 must be submitted through the IARD system by March 31.

The SEC has not indicated it will follow the same approach. Thus, if you are an SEC registered adviser, be prepared to file your Part 2A by March 31.

If you need help with drafting your Part 2A, please do not hesitate to contact Shane Hansen (shansen@wnj.com or 616.752.2145), Linda Paullin-Hebden (lpaullinhebden@wnj.com or 248.784.5159) or other members of the Broker-Dealer and Investment Adviser Law and Regulation Group.

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