Accurate, timely Form ADV filings protect your reputation and keep you aligned with the SEC’s expectations. When firms fall behind or overlook details, the consequences can be costly, resulting in deficiencies, penalties, and reputational damage.
With the right approach, you can turn this annual requirement into a smooth process.
1. Start Early and Audit Your Data
Data accuracy is imperative for accurate filings. Begin reviewing client lists, assets under management, ownership details, and service descriptions before the deadline. Early preparation gives you breathing room to resolve discrepancies and confirm consistency across Form ADV Part 1 and Part 2. As part of this early prep, assign clear responsibilities—who gathers data, who reviews disclosures, and who submits the filing. Defined roles prevent last-minute confusion and ensure nothing is overlooked.
Many firms can underestimate how long it takes to reconcile data from multiple systems, especially when manual processes are involved. Starting early reduces stress and ensures nothing is missed.
2. Stay Current on the SEC’s Requirements
Regulatory expectations shift constantly. The SEC has recently emphasized transparency in fee disclosures, detailed reporting on conflicts of interest, and stronger cybersecurity risk disclosures. These areas frequently surface during exams and, if overlooked, can lead to findings. Review guidance, enforcement actions, and interpretive updates regularly.
If your firm has introduced new products, strategies, or digital assets, confirm whether additional disclosures are required.
3. Update Disclosures and Policies
Your Form ADV should reflect your business as it operates today. Review disclosures related to fees, conflicts, disciplinary history, and services offered. If you’ve expanded into new markets or launched new strategies, make sure those changes are documented. Inconsistent or outdated disclosures are a common trigger for the SEC’s inquiries. Align your ADV updates with annual compliance policy reviews to maintain consistency across all documentation.
4. Leverage Technology for Efficiency
Manual processes slow you down and increase risk. Instead of relying on spreadsheets and email chains, consider compliance integrating technology that automates data collection, tracks changes, and streamlines filing. Technology solutions pull information from multiple sources into one system, which can reduce errors and improve accuracy. Automation also creates audit trails and version control, which are critical during exams. Firms that embrace technology can often see fewer deficiencies and faster turnaround times.
5. Document Everything for Exams and Audits
The SEC expects clear evidence of your compliance efforts. Maintain records of policies, procedures, data sources, and any changes made during the filing process. Organized documentation demonstrates diligence and makes exams far less stressful. Centralized storage ensures quick access during regulatory reviews and reduces the risk of missing information when it matters most.
Also, confirm well before the deadline that your firm’s SEC Investment Adviser Registration Depository (IARD) account is funded, and everyone who needs access to that system has proper credentials. Too often, firms scramble because they forgot to deposit the $225 filing fee, or a critical person cannot access the system. Heavy IARD traffic near the deadline can make it difficult to solve these problems. Quick checks early on can save you from last-minute headaches.
How ACA Helps Reduce the Filing Burden
Preparing Form ADV is complex, but it doesn’t have to be overwhelming. ACA delivers end-to-end support through expert guidance and full-service solutions. Our advisory team helps you interpret SEC requirements, update disclosures, and ensure accuracy, while our managed services team can take on the entire process so your team can stay focused on strategic priorities.
Ready to simplify your Form ADV process?