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Alternative Market Briefing

Form ADV 2A Trends 2025: What hedge fund managers should update now

Wednesday, October 01, 2025

Matthias Knab, Opalesque for New Managers:

Law firm Seward & Kissel has released its latest analysis of Form ADV Part 2A disclosures from a large, randomly selected set of top SEC-registered advisers focused on hedge funds, institutional SMAs, and closed-end funds. The study surfaces four clear trendlines shaping how managers disclose risks, fees, conflicts, and product scope in today's fast-moving regulatory, technological, and geopolitical environment.

1) New management-related disclosures

Advisers are expanding narrative around affiliated services (e.g., portfolio monitoring, diligence), use of artificial intelligence and machine learning, advisory committees for closed-end funds, family office buildouts, relationships with third-party vendors, and bespoke client terms (including side-letter considerations). Together, these changes reflect the operational complexity that scales with firm growth and regulation.

2) Fund expense transparency widens

Technology is a material driver: electronic report delivery and information systems (acquisition, development, maintenance) now appear more frequently as fund expenses. Managers also flag business development travel, investor annual meeting costs, background checks, and "new normal" lines such as cyber and crime insurance. Where pass-through models are used, brochures add greater detail to align with SEC ......................

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