Form ADV Annual Amendment Filing Checklist

It covers the annual updating amendment process for Form ADV, including reviewing firm information, advisory business changes, disciplinary disclosures, custody, assets under management, and other required updates. The checklist is meant to help you confirm what changed during the year and what must be reflected in the filing. It is focused on the annual amendment, not initial registration or routine quarterly maintenance.

Run it immediately after fiscal year end and work backward from the 90-day filing deadline. Many firms start the review in the first few weeks after year end so they have time to collect data, resolve discrepancies, and obtain approvals. If your disclosures change materially during the year, you should not wait for the annual cycle to begin reviewing them.

The DRI is usually compliance, legal, or the chief compliance officer, with input from operations, finance, portfolio management, and any business-line owners who control the underlying facts. The person running the checklist should be able to verify each item and route blocking issues to the right reviewer. For smaller firms, one compliance owner may handle most steps, but the checklist still benefits from named reviewers for data validation.

No. It is relevant to SEC-registered advisers and can also be adapted for state-registered advisers that file Form ADV or state equivalents with annual update obligations. The exact disclosure fields and filing workflow may vary by regulator, so the checklist should be customized to match the adviser’s registration status and jurisdictions. Use it as a template for the review process, not as a substitute for legal advice.

Common mistakes include missing the filing deadline, failing to update ownership or control changes, overlooking disciplinary disclosures, and submitting inconsistent information across schedules and brochures. Another frequent issue is relying on last year’s filing without reconciling current books, records, and business practices. This checklist forces a fresh review so the filing reflects current facts rather than stale assumptions.

An ad hoc process often depends on memory, email threads, and last-minute document hunts, which makes it easy to miss a disclosure or deadline. A checklist creates an auditable sequence of verification steps, assigns ownership, and makes blocking issues visible before filing. That is especially useful when multiple departments contribute data and sign-off is required.

Yes. You can add or remove checklist items based on whether the adviser has custody, performance fees, multiple offices, wrap programs, affiliated entities, or complex ownership. Smaller firms may keep it lean with a few key verification steps, while larger firms may split it into sub-checklists for data collection, review, and filing approval. The template should reflect the firm’s actual disclosure footprint.

Useful supporting sources include the prior year Form ADV, internal compliance calendars, ownership and personnel rosters, marketing review logs, disciplinary records, AUM reports, and custody or fee documentation. Many firms also link the checklist to task management, document storage, and approval workflows so each verification step has an owner and evidence trail. The goal is to make each item independently verifiable.

Treat the discrepancy as a blocking issue until the underlying fact is confirmed and the disclosure is corrected if needed. Assign the issue to the right DRI, attach the source document, and record the resolution before filing. If the discrepancy affects a required disclosure or timing obligation, escalate it through your compliance review path rather than marking it complete prematurely.