Excerpt from Financial Planning Magazine “Besides a newly mandatory documented annual review obligation for all RIAs regardless of whether they advise any private funds, the five other provisions could force some firms to hire auditors, examine possible conflicts of interest and create new quarterly reports, according to interviews about the reform package A “sizable percentage” of RIAs, especially those working with high net worth clients, currently use private funds in some capacity, according to Roberson.

“It's pretty substantial — if they're not a private fund advisor directly, they may be recommending or investing in third-party products,” Roberson said. “What are the vehicles and are there any potential conflicts of interest that you haven't factored into your initial disclosures? Those things will come up, even if you happen to have a small equity position in this and this is something you haven't previously disclosed and it was part of your private fund activities.”