Welcome to the ACN Form ADV Narrative Brochure Application. Form ADV Part 2 Help / User Guide

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1 Form ADV Help Welcome to the ACN Form ADV Narrative Brochure Application Form ADV Part 2 Help / User Guide (We are continually updating the Help User Guide adding some additional instructions and images. Please contact us if you have any problems or questions - Contact ACN ) INTRODUCTION This Help / User Guide contains instructions to be used with the ACN APP FORM ADV NARRATIVE BROCHURE APPLICATION for use by investment managers compiling their Form ADV Part 2 and registering with the SEC. The application adheres to the SEC requirements set forth in its Final Relase Number IA-3060 ( While the application is designed in accordance with SEC requirements, there is no relationship or agreements between Advisor Consultant Network, Inc and the Securities and Exchange Commission. This application is a tool for managers to use in compiling the Form ADV Part 2 document by converting from the old Form ADV Part II to the new narrative brochure Part 2A format and creating subsequent amendments to the document. This application provides the templates for the Firm Brochure, Wrap Fee Brochure and Brochure Supplement depending upon the needs of the investment adviser and a secure online platform for collaborative writing and review. The process includes three phases Setup, Writing, and Review. Please reference the link to the SEC requirements above for full instructions on which brochure is applicable to your situation, and what information is to be used in compiling your form. SPECIAL FEATURES Mapping This application includes images of the old Form ADV Part II document associated with each new required Item (as defined in SEC release IA- 3060) in the Setup templates. This feature makes for an easy and efficient transition to the new narrative requirement by helping you map your required Part 2 data to the corresponding Part II data in your old form. Table of Contents The required Table of Contents is automatically created in the process when you create your MSWord document. The Table of Contents is formatted for the layout for all the required Items with corresponding page numbers to your report. PDF Conversion The application creates both a final version of your brochure as a saved MSWord document and a copy is formatted as a PDF file as well. The PDF file format is required for submission to the IARD site as part of the new Narrative Brochure ruling by the SEC. ACN Assistance We stated this was a collaborative effort. ACN is prepared to assist in creating the narrative brochure in many ways. You have the option of completing the document all on your own or in some cases calling in the ACN experts to help in the process. The Assistance areas include: Setup, Writing, Formatting, and Amending on your IARD site. ACN APP ACCESS The FORM ADV NARRATIVE BROCHURE APPLICATION is a part of the ACN APP suite of investment compliance products, which also includes applications for Form 13F, Schedule 13G and Schedule 13D. To access the ACN APP suite, go to the ACN website and click on the ACN APP option on the right side of the Menu Bar. ACN Home Page When you select the ACN APP option you will be taken to a secure sign-in page where you will need your User ID and Password. The Sign-In page also contains the ACN License Agreement for working with the application. Please read the license agreement. By signing into the application you agree to the terms of the license agreement.

2 Sign-In Page Upon signing in, you will be taken to the ACN APP Home Page and have your choice of selecting those forms you have permission to use. (See next section Password Maintenance: Setting Up & Changing Your Password for additional sing-in information). In this instance choose the Form ADV button to access the Form ADV Part 2 Narrative Brochure application. ACN APP Home Page PASSWORD MAINTANENCE: SETTING & CHANGING YOUR PASSWORD Your User ID will be the address you entered on the Sign-Up Form at the time of your purchase. You will be given a temporary Password for your first entry to the site. After you enter your temporary Password you will be prompted to reset or enter your own Password.

3 Sign-In Screen If you forgot your Password, go to the Sign-In section and select the Forgot Password button. You will be prompted to enter and confirm your address. Upon pressing the Submit button, an will be sent to you with your Password. You can also change your Password in this area as well (Sign-In Screen). Select the Forgot Password button and a new menu will appear.

4 Change Password Screen Reset Password Screen CLIENT MENU PAGE Once you have entered the site you are taken to the Client Menu page. From here you will start the process of creating or amending your Form ADV Narrative Brochure. The Menu Bar offers the following options: Home - Takes you to the ACN Home Page Forms - Offers you the applications available to you in ACN APP suite of investment compliance products Help - Give you access to the Help / User Guides to the reports available on the ACN site. Sign-Out - Takes you out of the ACN site and keeps your browser open. If you are a new user your page will be blank: (IMAGE) (New) Client Menu Page If you have already created a brochure you will see a display of the brochure(s) you have created and the status of each brochure:

5 (Existing) Client Menu Page The Client Menu columns are defined as follows: Open - The folder icon is a link to your existing report. Create Date - The date you created the report. Status Date - The date of the last update to the report. Status Phase - status of the report Setup, Writing, Review. Year - The filing year of the report you are creating or amending. Form Type - The description of the report Firm Brochure, Supplemental Brochure and Wrap Fee Brochure. Preview - Opens your document in either HTML or PDF format. Click on the New Report button to start a new brochure. A menu will prompt you to select from the new report options: Firm - The Firm is the entity creating the report. The firm and the manager can be and often is one and the same. The firm can also be a compliance firm or a law firm creating a brochure for a manager. Manager - The name of the investment adviser for whom you are creating the brochure. Type - The type of brochure being created: Firm Brochure Form ADV Part 2A Supplemental Brochure Form ADV Part 2B (supervised individuals of the manager) Wrap Fee Brochure Form ADV Part 2A, Appendix 1 Date - The date you are creating the report. New Report Menu After you have filled out the form, click on the OK button and you will be taken to the Setup page for your particular brochure.

6 PHASE 1 SETUP The Setup page is used primarily for gathering and organizing information under the proper Items corresponding to the requirements of the SEC Final Release IA-3060 (SEC Final Release No. IA-3060 and instructions Form ADV Part 2 Narrative Brochure). Here you can copy and paste data from your old ADV Part II and Schedule F into a template before you start the writing or narrative conversion. The instructions for each Item and each Sub-Item will prompt you to enter information that is required to be disclosed. Please keep in mind the following recommendations explicitly stated by the SEC: You must respond to each item in Part 2. You must include the heading for each item provided by Part 2 immediately preceding your response to that item and provide responses in the same order as the items appear in Part 2. If an item does not apply to your business, you must indicate that item is not applicable. If you have provided information in response to one item that is also responsive to another item, you may cross-reference that information in response to the other item. The brochure should discuss only conflicts the adviser has or is reasonably likely to have, and practices in which it engages or is reasonably likely to engage. Under federal and state law, you are a fiduciary and must make full disclosure to your clients of all material facts relating to the advisory relationship. As a fiduciary, you also must seek to avoid conflicts of interest with your clients, and, at a minimum, make full disclosure of all material conflicts of interest between you and your clients that could affect the advisory relationship. The items in Part 2 of Form ADV are designed to promote effective communication between you and your clients. Write your brochure and supplements in plain English, taking into consideration your clients level of financial sophistication. Your brochure should be concise and direct. Firm Brochure Setup Page

7 Supplement Brochure Setup Page Wrap Fee Brochure Setup Page The Brochure Menu Option Bar offers different functions while working within the Setup template. The most important is the Save button. Make sure you save your work upon closing. It is recommended to save more frequently, for example as you move from one Item to another. Save - Saves the data in the template. Preview - Setup Opens a preview of the brochure you are working on in your browser.

8 Close - Closes the brochure you are working on and returns you to the Client Menu Page Brochure Menu Bar The Setup template lists each Item to be included in the report on the left panel. When you select the Item name, the template will appear on the right panel where you will be instructed on how to answer or complete the form. An Item may include sub-sections that will require an answer. Use the scroll bar on the right of the panel to scroll down or up to enter your information. The template is formatted as an HTML file and can be previewed at any time by pressing the Preview button. Upon entering all the data for each of the Items the next phase is the Writing phase. ACN Setup Assistance You have the option of requesting assistance from ACN to help you populate the Setup page by copying and pasting your data from your old Form ADV Part II and Schedule F data into the new Part 2 narrative template. By selecting the ACN Setup Assistance button (see Brochure Menu Bar) a drop down menu will initiate an with the following instructions: We are contacting ACN for assistance in helping us with the Setup phase in creating the ACN Form ADV Part 2 Narrative Brochure. We understand the cost for the standard service is $250 and that we will be sent an invoice for this service. Attached is a copy of our Form ADV Part II. We understand that once ACN has finished with the Setup phase they will contact us with further instructions. Attach your old Form ADV Part II as either a MSWord document or an editable PDF file to the . You also have the ability to add your own comments. Select the Send button and the will be sent to ACN and a copy to the user currently signed-in to the application. ACN Setup Assistance Button Changing Status: From Setup to Writing This feature will move the process from the Setup phase to the next phase: Writing. By moving from the Setup phase to the Writing phase, the application converts the data into an MSWord document. Notes, comments or instructions can be added to each version. The document can then be downloaded for editing purposes and uploaded back into the application in order to save the document in the application. A record of all the documents is saved in the database. When this is completed and the Setup page information is converted to an MSWord document, the Status Bar changes from Setup to Writing.

9 Change Status Menu PHASE II WRITING The Writing phase offers the user a MSWord document that can be easily edited. By converting the Setup template or form information into a MSWord formatted document the Plain English narrative description of the investment manager can be performed more efficiently. Writers Narrative Screen Download the MSWord file to begin editing the Setup information and turning the document into a narrative brochure. When you have made your changes to the document you will come back to this page and upload the file back into the application. You may do this as many times as you wish with each document being saved as a record. You have the option of deleting extra copies as you progress. You can also invite anyone you wish to review the document before you move to the next phase. You have the option of either sharing your user codes or creating an additional user for your brochure by setting a new Contact (See Administrative Functions section). ACN Writer Assistance You have the option of calling in a team of professional writers to edit your file and turn the information into a narrative document. The writers are thirdparty contractors with ACN; they are proven copywriters who have an understanding of the new SEC Narrative Brochure rule, the SEC s Plain English Handbook, and experience in creating and working on narrative brochures. You have the option of calling in the writers at any point. In other words you may wish to start the process and re-work the MSWord document and call in the writers after you are done. By selecting the ACN Writers Assistance button (see Writers Narrative Screen) a drop down menu will initiate an with the following instructions: We are contacting ACN for assistance in converting the Setup phase information for the Wrap Fee Brochure into a Narrative Brochure. We understand that ACN will download the data from our page and deliver it to their team of copywriters who will in turn convert the data into a narrative brochure using plain English. We understand that the cost of the service is $150/hour for up to 20 hours of work; $120/hour for over 20 hours, and $100/hour for additional editing. (Additional editing includes reworking or changing the document after I have a chance to review.) We understand that once ACN has finished with the conversion they will upload the document back to our page and contact us with further instructions. (A copy of this will be sent to the user's address.) Select the Send button and the will be sent to ACN and a copy to the user currently signed-in to the application.

10 Writers Assistance Notice ACN will download your file and manage the process of delivering it to the writers and bringing it back onto the application for your review. You will be notified when they are finished writing. If after reviewing their work and you add additional information or you wish to have them rework certain Items you can make notes to your document and send it back to the writers. Upload Document Upon converting the MSWord to the narrative the document must be uploaded back to the application. At any stage in editing and reworking the MSWord document the file can be uploaded as well. Select the Upload Document button and a drop down menu will appear. Press the Select File button in order to browse for your document. There is a text field that will allow you to add any notes describing the document, i.e. what changes were made, what needs to be done, etc. Upload Document Menu Changing Status: From Writing to Review After you or the ACN writers are finished with converting the information into a final draft of the narrative document the status will need to be changed to Review. Select the Change Status button and move the document to the Review phase. PHASE III REVIEW & COMPLETE Review is the final phase. The user can call in any interested parties whether it is outside legal counsel or in-house compliance and marketing staff to review and edit the MSWord document. Select the Review tab in order to view the details of your document.

11 Manager Review Screen At this stage you may want to further edit the document or you may want others to review the document. Each time a user downloads the document and reviews and edits, you will need to upload the document back into the application. Each time a document is uploaded back to the application, a new status date is created and notes can be included with the uploaded version. The notes may indicate who reviewed and edited the document by indicating the person s name or other identifying characteristics. (IMAGE) Changing Status: From Review to Complete Upon your final review you will want to change the status to Complete. When you are finished with the Review phase select the Change Status button and move the document to the Complete phase. You will only see this option if the document is in the Review phase. Changing the status to Complete will save the document as a permanent record for future amendments and will also convert the document to a PDF file to be used for posting on the FINRA/IARD site and your website if you so desire. ACN ADD-ON SERVICES Formatting ACN will assist you in the final formatting of your document. We can assist in adding images, formatting the final layout, and editing the document for the final version. Printing & Mailing ACN partners with a publicly owned third party printer who is ready to assist in printing and mailing your document in large numbers. IARD Submission ACN is an IARD Filing Agent and will assist you in submitting an amendment on the IARD System in order to post your narrative brochure on the system. Supplement Brochures ACN will assist in creating large numbers of Brochure Supplements ACN HELP & SUPPORT For questions and suggestions, please contact us. Contact ACN Thank you. Copyright Advisor Consultant Network, Inc. All rights reserved.

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