Investment Advisers registered with the US Securities and Exchange Commission (the "SEC") as of December 31, 2010, and that have fiscal years ending December 31, 2010 through April 30, 2011 must start delivering brochure supplements (Part 2B Form ADV) to new and prospective clients by July 31, 2011 and to existing clients by September 30, 2011.
Advisers with fiscal years ending after April 30, 2011, must deliver such brochure supplements within 120 days after the end of their fiscal year. Investment Advisers who filed their applications for registration between January 1, 2011 and April 30, 2011, should already be delivering such brochures to new and prospective clients, as well as existing clients.
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