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compliance
The SEC requires both Exempt Reporting Advisers and SEC-Registered investment advisers to submit the Form ADV Annual Updating Amendment before their fiscal year-end, which often falls on March 31st. The Form ADV is a publicly-viewable document that is distributed to clients and contains information about a firm’s business models, fee structures, additional services, and more. This document must be completed accurately to ensure consistency throughout other regulatory filings and deliverables, in an effort to avoid SEC examination deficiencies. A common category for SEC deficiencies is directly related to the accuracy of and consistency between various portions of the Form ADV.
To be considered complete, the Form ADV Annual Updating Amendment must update all applicable responses to the items in Part 1A, 1B, and 2A, as well as corresponding sections of Schedules A, B, C, and D and all sections of Schedule R for each relying adviser (as applicable). A firm’s Form ADV Part 2B, although often not uploaded as part of the annual updating amendment, must also be reviewed and updated on an annual basis. If there are no material changes, an investment adviser may, but is not required to, submit as part of its annual Form ADV amendment, an updated version of its client relationship summary (Part 3 of the Form ADV, also known as the “Form CRS”).
If would like assistance with the annual updating amendment to your Form ADV, please reach out to us!
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