As an investment adviser registered with the SEC,1 you will be required to amend your Form ADV from time to time.2 The following summary is designed to assist you by identifying the types of information on your Form ADV that require amending and the timing for filing such amendments with the SEC, as well as whether you are required to deliver such amendments to your clients. The summary is divided into two sections: (i) annual updating amendments that are required to be filed with the SEC each year (“annual amendments”) and (ii) other-than-annual amendments (“interim amendments”). As a reminder, Form ADV consists of the following parts:
- Part 1 (consisting of Parts 1A and 1B) is primarily for SEC use and requires information about an investment adviser’s business, ownership, clients, employees, business practices, and certain disciplinary events of the adviser and its employees.3
- The Brochure (Part 2A) is primarily directed to clients and consists of plain English disclosures of, among other things, the investment adviser’s business practices, investment strategies, fees, conflicts of interest, and disciplinary information.4
- The Brochure Supplement (Part 2B) is also primarily directed to clients and contains information about employees that provide investment advice to clients, including educational background, business experience, other business activities, and disciplinary history.
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