The SEC has recently updated its Q&A on Part 2 of Form ADV. It clarified certain sections of the new form and explained how to respond in certain scenarios. Key take-aways from the update include:

Key Trigger Dates
Currently registered SEC advisers with a fiscal year-end between December 31, 2010 and April 30, 2011 must deliver the new Form ADV Part 2 and brochure supplements to new and prospective clients by July 31, 2011.

Currently registered SEC advisers with fiscal year-ends between December 31, 2010 and April 30, 2011 must deliver the new Form ADV Part 2 and brochure supplements to existing clients by September 30, 2011.

Advisers registering with the SEC between January 1, 2011 and April 30, 2011 must begin delivering the new ADV Part 2 and brochure supplements to new and prospective clients by May 1, 2011 and existing clients by July 1, 2011.