It’s that time of year again! If your RIA’s fiscal year ended on Dec 31st, 2020, your Form ADV and annual filings are due March 31st, 2021. If little has changed, it may be tempting to simply update your AUM, personnel headcount, and file—though, that could leave your firm at risk of missing important SEC and state regulatory changes and updates.
Just as the SEC and states’ rules and regulations change gradually over time, so, too, do your firm’s compliance needs. Take this opportunity to have a compliance professional review your ADV and brochure, especially if you used a template-based service when forming your RIA.
Some common questions that advisors should ask themselves before submitting their annual filing with the SEC or registered state include:
Have you had a change in ownership or executive officers?
Did you add any new advisors, any new product lines, or another business line?
Did you open or close any locations?
Did you take a PPP loan?
Have there been any disciplinary events?
Have you added or removed any state reporting requirements?
Does your firm brochure/relationship summary properly reflect your fee schedule?
Do you have outside business activities (OBAs) that require disclosure?
If you answered “yes” to any of the questions listed above, your Form ADV needs to be updated with additional amendments before it can be filed.
AdvisorLaw’s experienced team can answer your questions, research the needs specific to your firm, and provide guidance regarding the most common compliance issues experienced by RIA firms. As your firm grows and evolves, AdvisorLaw is there to assist you at every step of the way.
Learn more about our ongoing RIA Compliance Services.