Disclosure of “Sub-Adviser” Relationships
NCCI can assist your organization in the preparation and filing of disclosures. Additionally, NCCI can manage, monitor and update your organization´s Public Disclosure Program activities.
Given the current challenges of the investment arena, you may decide to use the services of another investment adviser (“sub-adviser”) to provide your firm with certain expertise or services that you will ultimately use on behalf of your clients. In this case, your firm would be a client of the sub-adviser. Or, perhaps you elect to have the subadviser provide services or expertise tailored to the needs of one or more of your firm’s specific advisory clients. Alternately, your firm may be the “sub-adviser” in either capacity to another investment adviser.
The investment adviser needs to disclose the relationship and services to its advisery clients. Both the advisery contract and Form ADV need to contain disclosures related to the use of sub-advisers and the nature of such sub-advisory agreements.
NCCI can assist in defining the disclosure needs; reviewing related documents; and, guiding your firm in implementing “sub-adviser” relationships.