---
title: "List items for a Form ADV annual updating amendment"
url: "https://ailawframework.com/practice/financial-services-regulation/prepare-the-licensee-s-annual-financial-statements-lodgement/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A28-X20261018-2-US"
practice_area: "Financial Services Regulation (AFSL/ASIC/credit)"
tier: "red"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# List items for a Form ADV annual updating amendment

> List the fiscal year-end date stated in the file and the Part 1 or Part 2 items a change note says have changed. Write no amendment and no financial statements.

Canonical page: https://ailawframework.com/practice/financial-services-regulation/prepare-the-licensee-s-annual-financial-statements-lodgement/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Financial Services Regulation (AFSL/ASIC/credit)](https://ailawframework.com/practice/financial-services-regulation.md) |
| Human involvement | Red: Lawyer writes; AI may check, clarify or collect data |
| How AI is used | List the fiscal year-end date stated in the file and the Part 1 or Part 2 items a change note says have changed. Write no amendment and no financial statements. |
| What the lawyer must review | 17 C.F.R. section 275.204-1(a)(1) requires an adviser to amend Form ADV Parts 1 and 2 at least annually, within 90 days of the end of the adviser's fiscal year, and more frequently if the instructions to Form ADV require it. Part 3 is amended at the frequency those instructions require. Paragraph (b)(1) requires electronic filing through IARD of amendments to Part 1A, Part 2A, and Part 3, unless a continuing hardship exemption under section 275.203-3 applies, in which case paragraph (b)(2) requires a paper filing mailed to FINRA. Brochure supplements under Part 2B are not filed with the Commission. Paragraph (c) requires an annual filing fee each time the annual updating amendment is filed. No portion of the fee is refundable. The amended Form ADV is not accepted by FINRA, and is not considered filed with the Commission, until the fee is paid. Paragraph (d) says each amendment required under the section is a report within sections 204 and 207 of the Act. The note to the section says a summary of material changes that is not included in the brochure must be filed as an exhibit to Part 2A in the same electronic file, and that an adviser who is not required to prepare a brochure, a summary of material changes, an annual updating amendment to the brochure, or Form CRS is not required to file them. This rule does not require audited financial statements. The lawyer prepares the amendment. The tool writes nothing that is filed. The Cornell page is not the official edition. |
| Written for | United States |
| Applies to | [Prepare the licensee’s annual financial statements lodgement](https://ailawframework.com/practice/financial-services-regulation/prepare-the-licensee-s-annual-financial-statements-lodgement.md) |

## Checking plan

- What the AI does: List the fiscal year-end date stated in the file and the Part 1 or Part 2 items a change note says have changed. Write no amendment and no financial statements.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- This is not an annual financial-statement lodgement.
- Do not invent a custody-rule audit requirement.
- Confirm the official edition. The Cornell page is a copy.

## Sources

- [17 C.F.R. section 275.204-1, Amendments to Form ADV](https://www.law.cornell.edu/cfr/text/17/275.204-1) (checked 2026-10-22)
- [Investor.gov, Form ADV](https://www.investor.gov/introduction-investing/investing-basics/glossary/form-adv) (checked 2026-10-22)
- [ABA Formal Opinion 512, Generative Artificial Intelligence Tools (29 July 2024)](https://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/ethics-opinions/aba-formal-opinion-512.pdf) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*