An investment adviser firm must give a firm brochure to each client before or at the time you enter into an advisory agreement with that client. See SEC Rule 204-3(b) and similar state rules.
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When does my investment adviser firm need to provide clients with its updated Form ADV Part 2A brochure?
November 01, 2019
The updated Form ADV Part 2A brochure will need to be provided going forward to all new clients and existing investment advisory clients requesting a current version of the brochure. However, an investment adviser firm is not required to send a revised Form ADV Part 2A brochure to all existing investment advisory clients every time a material change is made. An investment adviser firm only needs to deliver once per year no later than 120 days after the investment adviser firm’s fiscal year-end either (1) the current Form ADV Part 2A brochure with material changes made within the prior one-year period or (2) a summary of material changes made within the prior one-year period with an offer to provide a complete copy of Form ADV Part 2A brochure upon request. This is commonly referred to as the “annual offer”.
