For investment advisers, regulatory compliance is a cornerstone of operating a successful and sustainable firm. One of the most critical filings required by the U.S. Securities and Exchange Commission (SEC) and state securities authorities is Form ADV—a comprehensive disclosure document that provides regulators, clients and prospective investors with vital information about an adviser’s business.
What Is Form ADV?
Form ADV is the uniform registration document for investment advisers and serves multiple purposes. It consists of two primary parts:
Part 1: Submitted electronically through the Investment Adviser Registration Depository (IARD), this section collects essential details about the advisory firm, including:
- Ownership and organizational structure
- Regulatory history
- Types of clients served
- Assets under management (AUM)
- Disciplinary disclosures, if applicable
Part 2 (brochure and brochure supplement): This portion is client-facing and clearly outlines:
- The adviser’s services, fees and compensation structure
- Potential conflicts of interest
- Investment strategies and risks
- Disciplinary history (if any)
In addition, Form ADV Part 3 (Form CRS) may be required for SEC-registered advisers to retail investors, summarizing key aspects of their services and fees in a standardized format.
Who Must File Form ADV?
Investment advisers with $100 million or more in assets under management (AUM) must register with the SEC, while those managing less than $100 million typically register with state regulators. Private fund advisers exceeding $150 million in AUM are required to file as exempt reporting advisers (ERAs), but must still submit certain sections of Form ADV.
Filing and Annual Updates
Firms must file their initial Form ADV before commencing business as a registered investment adviser. The due date for the 2025 Form ADV filing is March 31, 2025.
Additionally, advisers must update Form ADV annually within 90 days of the end of their fiscal year and amend it promptly whenever material changes occur—such as changes to business practices, fees, ownership or disciplinary events.
Regulators closely scrutinize Form ADV for transparency and accuracy. Misstatements, omissions or failure to update material information can lead to regulatory action, fines and reputational damage.
How Adviser Compliance Consulting Can Help
Navigating Form ADV requirements can be complex, especially as regulatory expectations evolve. Adviser Compliance Consulting specializes in proactive compliance solutions, offering outsourced chief compliance officer (CCO), deputy CCO support and more to ensure accurate filings, ongoing compliance monitoring and risk mitigation. Our team helps firms streamline their compliance obligations while staying ahead of regulatory challenges.
Contact us for more information on how we can support your compliance program.
