An investment adviser is required to deliver to each client, annually within 120 days after the end of the investment adviser’s fiscal year and without charge, if there are material changes to the investment adviser’s brochure since the investment adviser’s last annual updating amendment:
(1) a current copy of the investment adviser’s disclosure brochure (Form ADV Part 2A or if a wrap-fee client, Form ADV Part 2A Appendix 1); or
(2) a summary of material changes to the investment adviser’s disclosure brochure with an offer to provide a current copy of the disclosure brochure upon request.
If an investment delivers the summary of material changes, then the required offer to provide a current copy of the disclosure brochure must include the investment adviser’s website address (if available), an e-mail address (if available), a telephone number by which a client may obtain the current disclosure brochure from the investment adviser, and the Investment Adviser Public Disclosure (IAPD) website address (http://www.adviserinfo.sec.gov/) .
Form ADV – Annual Offer Letter
Form ADV – Request/Receipt Log
Communication – Electronic Delivery – Client Authorization
The information contained in this sample calendar event is general in nature intended for educational purposes only and is not intended to be a comprehensive analysis of this topic. This sample compliance calendar event does not necessarily reflect the requirements of your investment adviser firm’s compliance manual. Securities regulations and corresponding deadlines are subject to change, and this calendar event may not reflect the most current requirements. This calendar event does not create a consulting engagement with RIA Compliance Consultants, Inc. and is not intended to constitute compliance consulting advice or apply to any particular investment adviser firm’s specific situation. Please consult the applicable securities regulator’s rules and published guidance for more details and the most current requirements about the topics referenced above.