Hello all from 40,000 feet. As I compose this column, I am on my way back to beautiful Princeton, N.J. (No, New Jersey is not just the smokestacks and oil cans that are situated on the New Jersey Turnpike) from client meetings and speaking engagements in Seattle and Portland. I am blessed to have met and worked with so many wonderful people and firms throughout the United States and Canada over the last 25 years.
As I write, I am approximately 24 hours from the fateful March 31, 2011, SEC deadline for filing new Form ADV Part 2A. I now know what it feels like to be a CPA trying to meet his April 15 deadline. I have reviewed approximately 1,500 Part 2As that my firm has drafted and will have filed by midnight tomorrow. I, and the marvelous people that I have the privilege to work with, are exhausted.
So, here is the “$100 million” question (yet another issue advisors will have to address by July of this year—stay tuned to future columns): Will all the stress and cost associated with this new Part 2A make a substantial difference for the investing public? Unfortunately, the truthful answer is no. Will the new Part 2A stop the next Madoff or Stanford? Absolutely not. To the contrary, future crooks (and there will always be future crooks, as well as current crooks who have as of yet gone undetected) may have the most eloquently drafted written disclosure statements.