Advisers with fiscal year end of December 31 have until March 30 to file their Form ADV. With the deadline looming, here are six last-minute tips to help you file accurately and on time.
1. Don’t Forget to Pay
Make sure you have enough funds in your IARD account as your filing will not be accepted without payment. In addition, do not wait until the last minute, as payment may take a few days to go through.
2. Stay Consistent
Some parts of Form ADV ask for the same information. Part 1A and Part 2A require the same information on AUM, types of clients, and descriptions of compensation arrangements, such as percentage of AUM or fixed fees. Parts 1A, 2A and Form CRS require information on services, fees, conflicts of interest and more. It is important to thoroughly review these sections to make sure the information is consistent and accurate across all three.
3. Reference and Update Other Essential Documents
Document client agreements, financial statements, website, and marketing collateral and update accordingly. Pull and organize documentation and assess if there are any discrepancies or incomplete information.
4. Apply a Standard Process and Procedure for Providing Information
For questions such as calculating RAUM or client classification, it is crucial to apply a standard procedure for such determinations and maintain supporting documents to back them up.
5. Consider New Regulations
When reviewing and revising information on your Form ADV, it is important to consider new regulations that need to be implemented, such as disclosing your marketing practices or the use of promoters.
6. Consider using Outside Counsel/Consultants
Take advantage of outside counsel or compliance consultants who can make your Form ADV filing more efficient. They can check for errors or omissions and provide you with suggestions to enhance your disclosures.
Jacko Law Group recommends early and ongoing preparation when it comes to filing Form ADV; however, we understand that it is a considerable undertaking, and we hope these last-minute tips help you in completing your Form ADV. We welcome any questions regarding Form ADV and can assist you with your filing. For more information, please contact us at 619.298.2880 or email info@jackolg.com.