Now that you have the ability to offer your clients Bitcoin ETFs, have you considered updating your ADV? These ETFs provide direct exposure to bitcoin through either spot prices or bitcoin futures which brings nuanced risk clients may not have experienced.

In most cases you have already disclosed you offerETFs, but I would caution with the newness and novelty of this product entry into the market,  it should prompt you to review your disclosures.  Disclosure and transparency to clients is a key item any regulator will look for when they review your client facing materials.  Review the bitcoin prospectus to see if there is disclosure language of a type you may not have already incorporated into your marketing materials.  Additionally, given the enthusiasm on this product there could be language the issuer has customized in the prospectus you could leverage.

ADV updates are due for those with annual year end schedules of December 31^st so a timely review given this new product launch.  RegVerse – your regulatory co-pilot – is here to assist if you would like a personal review of your ADV language so contact us today!

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