Record the annual Form ADV amendment date from the fiscal year end
Key facts
- Human involvement
- YellowClose supervision
- How AI is used
- From the adviser's filing record, record the fiscal year end and the date Parts 1 and 2 of Form ADV were last amended. Count 90 days from the fiscal year end the lawyer supplies. Do not decide that a further amendment was required, and do not apply a product-notice period.
- What the lawyer must review
- The lawyer decides whether 17 CFR 275.204-1 required an amendment. Paragraph (a)(1) says the adviser must amend Parts 1 and 2 of Form ADV at least annually, within 90 days of the end of the adviser's fiscal year, and more frequently if required by the instructions to Form ADV. Part 3 is amended at the frequency required by those instructions. The instructions were not opened. Paragraph (b) requires electronic filing of amendments to Part 1A, Part 2A, and Part 3 with the IARD, unless a continuing hardship exemption under section 275.203-3 applies. Brochure supplements under Part 2B are not required to be filed with the Commission. Paragraph (d) says each amendment required to be filed under the section is a report within sections 204 and 207 of the Investment Advisers Act, 15 USC 80b-4 and 80b-7. The eCFR page states the same annual 90-day requirement. The rule does not state a 30-day notice period for a change in a financial product.
- Written for / version
- United States versionUS
Who does what
| Role | What they do |
|---|---|
| Assistance | Do not begin AI assistance until the responsible lawyer has defined and confirmed its permitted scope. |
| Lawyer | Set the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output. |
Checklist
- Trace every relied-on figure to its source, confirm dates and assumptions, and independently recalculate totals or derived amounts.
- Calculate operative dates independently from the current rule and actual triggering event. Check exceptions and record the verified deadline.
- Check the current court or regulator requirements, prescribed form and attachments for the intended document and filing.
- Verify the applicable jurisdiction and the version of each relevant law, rule or instrument in force at the material time.
- Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
- Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.