May 16, 2008
Simplification of disclosures made to clients is a desirable objective. Uniformity of disclosures from firm to firm facilitate comparison of alternative advisers under consideration or under review by a consumer. The current "check the box and explain your answer on Schedule F" format allows for quick comparisons by consumers, and would facilitate computerized screening on specific adviser attributes once all Form ADV, Part II forms are filed online. Moving away from standardized question and answer formats make such due care comparisons more cumbersome for consumers to carry out.
An unintended consequence of moving to entirely narrative disclosures might be disclosure of practices and conflicts of interest in language that, while plain English, tends to obfuscate the issue at hand. On the other hand, there is little way around straightforward yes or no answers, and questions of degree can be clarified in the narrative that follows (what under the current form we now call Schedule F).
Retaining standard Q and A with quantitative answers useful for conducting automated screening, while also allowing advisers the lattitude to clarify answers by providing relevant detail, would seem to satisfy the need for qunatitative comparability while allowing for clarification of qualitative specifics.
Identical disclosure threshhold standards for state and federal registrants would also result in more useful comparability between firms and supervised persons under consideration or review by a consumer.