Five Considerations When Updating Form ADV
Hopefully, everyone has begun the task of completing the annual updating amendment to Form ADV. The 2016 Amendments, which became effective October 1, 2017, made the task a bit more labor intensive. As you respond to the amendments, you must not forget the basics:
- Line it up. What must align:
- Investment Advisory Agreement(s)
- Policy and Procedures Manual
- Business and Marketing Practices
- Parts 1 and 2 of Form ADV
- Mayday. As Yoda says, “do or do not” there is no “may.” If you have done an activity once, the activity is not a “may,” it is a “do.”
- Keep it fresh. Ask folks from Operations, Trading, Portfolio Management and Client Services to review Form ADV for accuracy. Use different people each year.
- For the record. Consider, if asked to provide evidence that you complete the activities described in your Form ADV, can you?
- Help is available. Check out the instructions (Form ADV and Form ADV Part 2) and the SEC’s FAQ.