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Form ADV Writing Effective Disclosures

October 28, 2020
10:45 AM - 12:00 PM CDT
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Course Description:

What constitutes “full and fair” disclosure? How does your Part 2A measure up? Last June’s SEC Interpretive Release on the meaning of “fiduciary” should have caused every adviser to carefully review and, if needed, revise Form ADV Part 2A disclosures in light of the SEC’s guidance. This session will not only review the current contours of “full and fair” disclosure, but will consider the specific examples highlighted by the Commission: the permissible (and impermissible) use of the word “may”, disclosure of securities allocation policies, and tailoring disclosures to the needs of retail clients.

Learning Objectives

After attending this session, attendees should be able to:

  • Analyze your disclosure documents to make sure they meet the most recent SEC interpretations
  • Create and modify disclosures that will withstand regulatory scrutiny
  • Differentiate disclosure criteria for retail and institutional clients

This virtual course is being taught as part of the Fall 2020 Compliance Conference. To learn more, visit our main conference webpage.

Gretchen Lee
Gretchen E. Lee
Chief Compliance Officer, Clifford Swan Investment Counselors


Gretchen joined Clifford Swan Investment Counselors in 2018 and serves as Chief Compliance Officer. Immediately before joining the firm, Gretchen managed Crown City Compliance, a compliance consultancy firm she founded in 2009. Previously, she was Chief Compliance Officer at Gamble Jones Investment Counsel and an Investment Associate at Engemann Asset Management.

Gretchen received her B.A. in Economics from Scripps College in 1992 and frequently volunteers for her alma mater. She particularly enjoyed helping develop curriculum for the college’s Financial Literacy Program. Gretchen supports her community by volunteering for Sierra Madre Middle School and Maranatha High School. She and her husband enjoy spending time in the outdoors with their son and daughter—hiking and snow skiing are the family’s favorite activities.


Drew Ahrens
Drew Ahrens
Senior ConsultantNRS


Drew Ahrens’ responsibilities as a Senior Consultant with National Regulatory Services include on-site compliance reviews, risk assessments, policies and procedures drafting and review, as well as other compliance related analyses for investment advisers, hedge funds and mutual funds.

Drew joined NRS in 2010 and has worked in the compliance field for the past 25 years. Prior to his current role, Drew has had extensive experience as Chief Compliance Officer with Atlantic Trust, FIM Group and Henderson Global Investors, and as CCO of their respective mutual fund companies. Most recently Drew had formed his own regulatory consulting firm, Crosswinds Consulting. Drew has over 20 years of direct experience working with mutual fund compliance and fund boards.

Drew has also worked for firms including PPM America as VP of Compliance, Cova Investment Advisory Corp. as Director of Investment Advisory Compliance and Van Kampen Asset Management in various compliance roles.

Drew’s unique background gives him a strong understanding of a firm’s regulatory and CCO responsibilities. He has exceptional experience with the Investment Advisers Act of 1940 and the Investment Company Act of 1940. He has worked with various financial products, some of which include fixed income, hedge funds, REITS, annuities, options, open-end and closed-end funds and private equity investments. Drew has also had experience with building successful compliance programs from the ground up.

Drew holds a Bachelor of Arts degree from Western Illinois University and has completed a mediation skills certificate program from Northwestern University.


For Whom: Designed to increase the professional competence of Investment Advisers.

Suggested Skill Level: Intermediate

Maximum Recommended Credit Hours for this session will include CLE, IACCP® and CPE.

CA MCLE = 75 minutes
IACCP® = 75 minutes
CPE = 75 minutes

For more information, check out the NRS Continuing Education Guide.