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When Should an RIA Update Form ADV?
Form ADV should reflect how your firm operates today, not simply how it operated at its last annual filing. For RIAs, the practical question is not only whether a change occurred, but whether that change triggers an amendment before the next annual update.
This article is the first in ACA Wealth’s six-part Back to Basics series, which expands the practical compliance fundamentals covered in our Back to Basics: Compliance Fundamentals for 2026 webcast. We begin with a question that comes up often for CCOs, compliance teams, founders, and firm leaders: Do we need to update Form ADV for this?
The answer depends on the type of change and the specific Form ADV item or disclosure affected. Some information must be amended promptly when it becomes inaccurate, while other information requires an amendment when it becomes materially inaccurate. It sounds simple, but firms can land at one of two extremes: waiting too long to address genuine material changes or treating every operational shift as an amendment trigger. For disclosures subject to a materiality standard, the analysis comes back to one central question: whether the information has become materially inaccurate.
Understand the Two Form ADV Amendment Tracks
RIAs generally have two Form ADV amendment tracks: annual updating amendments and other-than-annual amendments.
1. Annual Updating Amendment
Every registered investment adviser must file an annual updating amendment within 90 days of the end of its fiscal year. For calendar-year firms, the deadline is March 31 (or March 30th in a leap year).
This is a comprehensive review. Firms should confirm that the applicable information in Form ADV Parts 1, 2A, and 2B, along with required schedules, accurately reflects the business, its people, services, conflicts, and disclosures.
2. Other-Than-Annual Amendment
Firms may also need to amend Form ADV between annual filing deadlines.
Some Form ADV Part 1 items must be updated promptly when they become inaccurate, even if the change is not material. Other Part 1 disclosures, as well as information in the firm brochure and brochure supplements, generally require updating when they become materially inaccurate.
This distinction matters. An effective process does not treat every operational change as an amendment trigger, but it also does not wait for the annual filing cycle when a change requires a prompt amendment or current disclosures no longer accurately describe the firm.
What Does “Material” Mean for Form ADV?
There is no single bright-line test that answers every materiality question. The analysis is fact-specific and should consider the particular Form ADV disclosure involved and whether the change makes that disclosure materially inaccurate. Firms may also consider whether the information would be important to a reasonable client or prospective client in evaluating the advisory relationship. The analysis and conclusion should be documented.
A useful practical question is:
Would a reasonable client or prospective client consider this information important when deciding whether to hire, retain, or evaluate the firm?
If the answer is yes, review the specific Form ADV disclosure and applicable amendment requirements. Consider how a material change may affect how clients understand the firm’s services, investment approach, fees, conflicts, key personnel, or ability to meet its obligations.
A Practical Decision Framework
When a change occurs, use these questions to assess whether Form ADV disclosures should be reviewed and potentially updated.
Does the change affect investment management or client risk?
New strategies, asset classes, investment approaches, or risk exposures may require updated disclosure. if they make existing Form ADV information inaccurate or materially inaccurate
For example, a firm adding digital assets, leverage, private investments, or a materially different investment strategy should assess whether its current brochure still accurately describes its services, risks, and methods of analysis.
A key consideration is whether clients are receiving a service or assuming risks that are not adequately reflected in existing disclosures.
Does the change affect fees, compensation, or expenses?
A change in a fee schedule alone does not require an interim brochure amendment. However, a broader change to compensation arrangements, fee practices, expense allocation, or related conflicts may make brochure disclosures materially inaccurate.
Firms should evaluate not only the fee schedule, but also how fees are calculated, who receives compensation, what expenses clients bear, and whether the change creates or alters a conflict of interest.
Does the change affect the firm’s ownership, leadership, or operations?
Changes in ownership, legal structure, affiliates, or key personnel may trigger Form ADV amendment obligations depending on the specific Form ADV item or disclosure affected.
Whether a change requires an amendment depends on the specific Form ADV item affected. Firms should be able to demonstrate that they considered the applicable filing requirement and whether the change affected disclosures about the firm, its personnel, or its ability to provide advisory services.
Does the change involve a legal or disciplinary event?
Legal and disciplinary events require particularly careful handling. If an event makes disciplinary disclosures materially inaccurate, the firm may need to amend its brochure promptly and provide updated disclosure to existing clients.
This is an area where the filing requirement and client-delivery obligation can both be important. Compliance teams should escalate these events early and coordinate with legal counsel as appropriate.
Form ADV Materiality Checklist
Use this checklist when evaluating a change at your firm:
- ✓ Would a reasonable client consider this information important when deciding whether to hire or retain the firm?
- ✓ Does the change affect the firm’s investment strategies, methods, or the risks clients face?
- ✓ Does the change affect fees, compensation arrangements, or expense practices?
- ✓ Does the change involve key personnel, an ownership or legal-entity change, or a new affiliate?
- ✓ Does the change involve a legal, regulatory, or disciplinary event?
- ✓ Could the change affect the firm’s ability to meet its contractual obligations to clients?
- ✓ Does the change create a gap between the firm’s written disclosures and its actual business practices?
If the answer to any question is yes, review the specific Form ADV item or disclosure affected, document the analysis, and determine whether an amendment, client communication, or both may be required.
Do Not Overlook Delivery Obligations
Filing an amendment is not always the final step.
SEC-registered investment advisers generally must deliver a current brochure to a client before or at the time they enter into an advisory contract, subject to applicable exceptions. SEC-registered investment advisers subject to the brochure-delivery requirements also have an annual delivery obligation.
Within 120 days after fiscal year-end, advisers subject to this requirement generally must deliver either a current brochure that includes or is accompanied by a summary of material changes, or a summary of material changes accompanied by an offer to provide the current brochure without charge.
For certain disciplinary changes, firms may need to provide updated disclosures to existing clients promptly rather than waiting for the annual delivery cycle.
A sound compliance process connects the filing decision with the client-delivery decision. Updating Form ADV without considering how and when clients should be informed can leave a meaningful gap.
Form CRS Requires a Separate Review
Form CRS is related to, but separate from, Form ADV Parts 1 and 2. It should accurately describe the firm’s services, fees, costs, conflicts, standard of conduct, and disciplinary history for retail investors.
If information in Form CRS becomes materially inaccurate, SEC-registered firms must update and file it within 30 days. Firms must communicate material changes to existing retail investors within 60 days after the updates are required to be made.
Do not assume a Form CRS update can wait for the annual Form ADV amendment. When a material change affects retail-client disclosures, review both Form ADV and Form CRS.
View Form ADV Through an Examiner’s Lens
SEC examiners may look beyond whether a firm met its filing deadline. They can compare the firm’s disclosures with how the business actually operates.
A brochure that does not reflect a revised fee arrangement, new strategy, changed conflict, or material operational development can create a disclosure gap. Even where the underlying change was made in good faith, a delayed or incomplete response can raise questions about the firm’s compliance controls.
The stronger approach is to treat Form ADV as an ongoing disclosure document. Build a process that brings material business changes to compliance early, documents the analysis, and connects the filing decision to client-delivery requirements.
The Bottom Line
Materiality cannot be reduced to a single checklist item or deadline. It requires consistent judgment.
When a significant change occurs, ask: Would a reasonable client consider this important? If the answer may be yes, review the relevant disclosures promptly and document the decision. An unnecessary amendment may create some administrative burden. A missed required amendment can create a disclosure gap that is much harder to explain.
How ACA Can Help
Maintaining accurate regulatory disclosures requires coordination across compliance, legal, operations, and firm leadership. ACA Wealth helps RIAs strengthen core compliance processes, identify disclosure gaps, and build practical controls that support ongoing regulatory readiness.
Download ACA’s Back to Basics guide for practical compliance fundamentals your firm can apply throughout 2026.