Regardless of a firm’s registration (SEC or state), the Form ADV needs to be updated, at a minimum, on an annual basis and whenever a material change to the document occurs. The annual amendment to the Form ADV Part I must be filed within 90 days of the firm’s fiscal year end through the IARD system. The annual amendment is used to update items such as assets under management, number of clients, number of accounts, and number of employees. These items must be updated with information current as of a firm’s fiscal year end. At this time, the ADV Part II is not filed through the IARD system, but advisors need to review and update it as part of the annual amendment as well.
Category Archives: Form ADV
A common question asked by many advisors during the registration process is whether the firm needs to file the Form ADV Part II with the appropriate regulator.
Form ADV Part 2 – Still on Hold
June 14, 2005
The approval of the highly anticipated new Form ADV Part 2 is on hold once again. Apparently, the form is ready for implementation through the IARD system, and all that is necessary is final approval. In fact, the IARD system was updated earlier this year to accommodate the new form once it is formally approved. However the latest word is that with the departure of Paul Roye as Director of the Division of Investment Management, the SEC is waiting to approve the form until a permanent replacement has been named. In addition, the recent resignation announcement of SEC Chairman Donaldson may delay the release even further because Paul Roye’s replacement may not be announced until Rep. Christopher Cox is formally confirmed and appointed as the new SEC Chairman.
