An investment adviser is required to prepare and submit a completed Form ADV as part of the initial registration process. In addition to the review by the U.S. Securities and Exchange Commission (“SEC”) or state securities regulator(s) for purposes of determining whether to approve or deny an application for investment adviser registration, the Form ADV Part 2 is also used as the investment adviser’s disclosure document which is required to be provided to all investment advisory clients.
Registered Investment Advisors Can Utilize a Sample ADV Annual Offer Letter to Help Comply with Form ADV Part 2A Annual Delivery Requirements
April 17, 2013
An investment advisor firm registered with the U.S. Securities and Exchange Commission (“SEC”) must meet certain requirements concerning the delivery of the investment advisor firm’s disclosure brochure Form ADV Part 2A. Under SEC Rule 204-3(b), each year, within 120 days of the investment advisor firm’s fiscal year end, the investment advisor firm must deliver to every client an updated disclosure brochure that includes a summary of material changes or deliver to every client a summary of material changes that includes an offer to provide a copy of the updated disclosure brochure and information on how a client may obtain the brochure.