ADV Amendment March Deadline: What Investment Advisors Need to Know

Cory-Roberson Mar 20, 2025
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December FYE Firms:  As the March 31st deadline for the annual ADV amendment approaches, investment advisors must ensure compliance with SEC and state regulatory requirements. Form ADV is a crucial disclosure document that registered investment advisors (RIAs) must file with the SEC or state regulators to provide transparency about their business practices, fees, and conflicts of interest. This guide outlines essential filing requirements, deadlines, and best practices to maintain regulatory compliance.

What Is Form ADV?
Form ADV is a comprehensive filing required by the Investment Advisers Act of 1940 (and similar state securities regulators), consisting of multiple parts:

  • Part 1A: General business and operational details.

  • Part 1B: Required for state-registered investment advisors.

  • Part 2A (Brochure): Details services, fees, conflicts of interest, and disciplinary history.

  • Part 2B (Brochure Supplement): Information about key personnel.

  • Part 3 (Form CRS): A concise relationship summary for retail investors - for SEC firms and FINRA broker-dealers

March ADV Amendment Deadline
Investment advisors must file an annual amendment to Form ADV within 90 days of their fiscal year-end. For firms with a December 31st year-end, the deadline falls on March 31st. Failing to file on time can lead to compliance violations, penalties, and even enforcement actions.

Key Steps to Ensure Compliance

  1. Review Business and Operational Changes

    • Update AUM (assets under management) figures.

    • Disclose any changes in fees, ownership, or investment strategies.

    • Confirm the accuracy of disciplinary disclosures.

  2. Update Form CRS (Part 3)

    • Ensure clarity and accuracy in disclosures to retail investors.

    • Revise any material changes in services or conflicts of interest.

  3. Submit Filings via IARD

    • The Investment Adviser Registration Depository (IARD) system facilitates electronic submission.

    • Ensure state-registered firms also comply with local regulatory requirements.

  4. Verify State-Specific Filing Requirements

    • Some states require additional disclosures or fees.

    • Check if state notices or renewals are due concurrently with the ADV amendment.

Other Essential Filings and Compliance Considerations
Beyond the March ADV amendment, RIAs should keep track of these additional filing obligations:

  • Form PF: Private fund advisors with $150M+ in AUM may have additional reporting requirements.

  • Annual Compliance Review: Conduct an internal audit to ensure policies and procedures align with SEC rules.

  • Form U4 Updates: If personnel changes have occurred, update Form U4 promptly.

  • State Notice Filings: For advisors operating in multiple states, ensure notices and fees are up to date.

Best Practices for Compliance Success
✔ Plan Early: Start gathering data and reviewing disclosures at least 60 days in advance.
✔ Engage Compliance Experts: Consider working with compliance consultants or legal counsel.
✔ Maintain Accurate Records: Document all amendments and internal reviews for audit readiness.
✔ Monitor Regulatory Updates: Stay informed about SEC rule changes that may affect disclosure requirements.

Final Thoughts
Timely and accurate ADV amendments are critical for maintaining regulatory compliance and investor trust. By proactively reviewing and submitting required filings, investment advisors can avoid penalties and strengthen their firm's transparency and credibility. If you need guidance on Form ADV compliance, consult with a professional compliance expert to navigate the complexities of SEC and state regulations effectively.

Need assistance with your Form ADV filing? Contact a compliance consultant today to ensure your submission is accurate and timely!

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