On June 8, 2012, the Division of Investment Management of the Securities and Exchange Commission (the “SEC”) issued responses (the “Responses”) to two questions regarding reporting on Part 1A of Form ADV. The first question related to Item 1.O of Form ADV, which requires an investment adviser to report whether it had $1 billion or more in assets on its balance sheet on the last day of its most recent fiscal year. The Responses clarify that “assets” refers to the investment adviser’s total assets and not the assets managed on behalf of clients. Thus, for example, an investment adviser that has $5 billion in regulatory assets under management but only $300 million in total assets on its own balance sheet for the most recent fiscal year would answer “no” to Item 1.O.

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