The March ADV filing deadline might be in the rearview mirror, but for SEC and state-registered investment advisors (RIAs), the work is far from over. Once your Form ADV is filed, it’s critical to shift focus toward ongoing compliance obligations, risk mitigation, and strategic planning for the rest of the year.
Here’s a comprehensive checklist of what investment advisors should prepare for post-ADV filing season to stay ahead of regulatory expectations and industry best practices.
1. Distribute the Updated ADV Part 2 to Clients
After updating and filing your Form ADV Part 2, you are required under Rule 204-3 to deliver the updated brochure (or a summary of material changes) to your clients within 120 days of your fiscal year-end. Most firms wrap this up in Q2, but it’s worth scheduling client distribution early to avoid compliance lapses.
Keywords: ADV Part 2 delivery, Form ADV client update, annual brochure distribution
2. Conduct Your Annual Compliance Review
SEC Rule 206(4)-7 and many state regulations require RIAs to conduct and document an annual review of their compliance program. Post-ADV season is the perfect time to:
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Evaluate the effectiveness of your compliance policies
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Document risks and corrective actions
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Review conflicts of interest disclosures
This review should be well-documented and signed off by the Chief Compliance Officer (CCO) or designee.
Keywords: RIA annual compliance review, SEC compliance obligations, investment advisor annual audit
3. Update Policies and Procedures
Your compliance manual should reflect any operational, regulatory, or personnel changes that may have occurred over the past year. After your Form ADV is filed, revisit your policies and procedures to ensure:
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They align with your updated business model
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They address new or emerging risks (e.g., AI usage, crypto custody, remote supervision)
Keywords: RIA compliance manual, investment advisor procedures, updated compliance policies
4. Review Cybersecurity Protocols
Cybersecurity remains a hot button for both the SEC and state regulators. Use this post-ADV window to:
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Test and update your Incident Response Plan
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Reassess vendor due diligence and access rights
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Schedule a phishing simulation or cybersecurity training for staff
Don’t forget to document all risk assessments and any changes to security controls.
Keywords: investment advisor cybersecurity, SEC cyber rules, cybersecurity risk assessment
5. Review Marketing Practices Under the New SEC Marketing Rule
With the SEC’s modernized Marketing Rule (Rule 206(4)-1), it’s critical to ensure that your performance advertising, testimonials, and social media posts comply with current requirements. Review:
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Your processes for approving marketing materials
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Documentation for hypothetical or back-tested performance
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Disclosures around endorsements and paid promotions
Keywords: SEC marketing rule compliance, RIA advertising regulations, testimonial rule for advisors
6. Validate Your Books and Records
Now is a good time to verify that your books and records are accurate, complete, and easily accessible. Make sure you're compliant with Rule 204-2, especially around:
Cloud storage? Hybrid firm? Ensure your records are properly backed up and that you can retrieve them on request.
Keywords: investment advisor recordkeeping, SEC books and records rule, RIA document retention
7. Conduct a Fee and Billing Review
Regulators continue to scrutinize advisory fee arrangements. Post-ADV season is ideal for reviewing:
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Fee disclosures vs. actual billing practices
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Reasonableness of fee calculations
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Consistency across clients and platforms
This step helps mitigate future exam risk and avoid potential client disputes.
Keywords: RIA fee audit, investment advisor billing practices, SEC fee disclosure rules
8. Prepare for a Regulatory Exam
Regulatory exams can come with little notice. After filing Form ADV, use the time to:
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Ensure all required documents are current and accessible
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Review past deficiency letters and exam feedback
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Conduct mock interviews or internal readiness checks
Being proactive can help minimize disruption and improve your standing during an actual exam.
Keywords: SEC exam prep, RIA audit checklist, investment advisor mock exam
9. Update Your Business Continuity and Succession Plan
Firms are expected to maintain an actionable Business Continuity and Succession Plan. Make sure:
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Emergency contacts and vendors are current
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Succession plans are documented and realistic
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The plan has been tested (or is scheduled to be)
Keywords: investment advisor succession planning, RIA continuity plan, disaster recovery plan compliance
Final Thoughts
While Form ADV season may be over, it kicks off a crucial window for RIAs to solidify their compliance foundation for the rest of the year. By taking a structured, proactive approach now, your firm can minimize regulatory risk and maximize operational readiness.
Need help with compliance or planning your post-filing season workflow? Contact Cory Roberson at: cory@fincompliance.io for customized support tailored to SEC and state-registered investment advisors.