Form ADV annual amendment deadline
SEC · Annually · 90 days after fiscal year end
An SEC-registered investment adviser files an annual updating amendment to Form ADV Parts 1 and 2 within 90 days of the end of its fiscal year (17 CFR 275.204-1(a)(1)). For a December 31 fiscal year end, that's March 31, or March 30 in a leap year.
Check the date against your own records.
What to update
- Part 1A, filed through IARD
- Part 2A, the brochure
- Part 3, the relationship summary (Form CRS), as often as the Form ADV instructions require
Between annual amendments
The annual amendment isn't the only one. Rule 204-1 also requires you to amend Form ADV more often when its instructions say so, so check them whenever something in your filing changes.
Telling your clients
If your brochure has changed materially since the last annual amendment, deliver to each client, free of charge, the current brochure or a summary of the material changes that offers the brochure, within 120 days of your fiscal year end (17 CFR 275.204-3(b)(2)). For a December 31 year end, that's April 30, or April 29 in a leap year.
Also on the calendar
Private fund advisers with at least $150 million in private fund assets also file Form PF within 120 days of the fiscal year end, and managers of $100 million or more in 13(f) securities file Form 13F every quarter.
Get reminded before it's due
Regmindr tracks this alongside the rest of your compliance calendar, and emails your team before each deadline. Set it up from your year end in about two minutes.
Sources
- 17 CFR 275.204-1: Amendments to Form ADV
- 17 CFR 275.204-3: Delivery of brochures and brochure supplements
This page is a summary, not legal or regulatory advice. The rules in the sources above take precedence.