Registration is not a one-time event. Once a year, every registered investment adviser has to revisit its Form ADV and file an annual updating amendment, confirming that its disclosures still match reality. It is a routine obligation and a common source of avoidable findings.
The annual updating amendment is generally due within a set number of days after the firm's fiscal year end, commonly framed as within ninety days. It requires reviewing the entire Form ADV, both the structured Part 1 and the client brochure, and updating anything that has changed: assets, personnel, services, fees, conflicts, and disciplinary history.
The annual amendment is a floor, not a ceiling. Certain material changes, to disciplinary information or other key items, must be updated promptly when they happen, not held until the annual cycle. Clients must also generally receive updated brochure information. A firm that only touches its ADV once a year can fall out of compliance between filings.
The failure mode is treating the amendment as a formality, filing it without genuinely reconciling the disclosures against how the firm now operates. Examiners compare the ADV to reality, and a stale or inaccurate filing is exactly what they flag. The amendment is an annual honesty check, and it should be done like one.
Once a year, reconcile the paper to the firm.
Greenridge L&C Advisors is a compliance consultancy, not a law firm. This is general information, not legal advice.