With 2025 in the rearview, many registered investment advisers and exempt reporting advisers with a December year-end turn their focus towards reviewing and preparing their firm Form ADV amendment. Timely and accurate submissions are critical to maintaining regulatory compliance and avoiding potential deficiency or operational issues. Blueprint GRC is here to highlight the key considerations and best practices for December year-end advisers.
Key Considerations:
- Timing of Submission
- Form ADV amendments should reflect the adviser’s fiscal year-end data no earlier than 31 December. While many advisers will use figures from the calendar year-to-date, so long as the entirety of the filing is completed as of the same date, then any date between 31 December and date of submission may be used.
- Submissions are due within 90 days following the fiscal year-end (Tuesday 31 March for December year-end advisers).
- Accuracy of Information
- Review Part 1 and Part 2 for any changes in assets under management (AUM), change in clients or launch of new private funds, business operations, ownership structure, and disciplinary history.
- Ensure that Part 2A (brochure) and Part 2B (brochure supplement) reflect any material changes in advisory services, fees, conflicts of interest, or personnel.
- Material Changes and Disclosures
- Disclose material changes promptly, even if they occur after the fiscal year-end but before filing.
- This includes changes in key personnel, new strategies, client types, or any legal or regulatory matters.
- Funding your Investment Adviser Registration Depository (IARD) Account
- Before submitting your annual updating amendment, fees must be deposited into the firm’s IARD Flex-Funding Account.
- Review your account in advance to determine if any deposits are needed as transfers can take several days. Payments can be made via check, wire transfer, or electronic payment/transfer.
- Before submitting your annual updating amendment, fees must be deposited into the firm’s IARD Flex-Funding Account.
- Client Part 2A (brochure) Delivery (Registered Investment Advisers Only)
- Within 120 days of its fiscal year-end, an adviser must deliver to each client either:
- An updated Part 2A (brochure) that includes a summary of material changes (or is accompanied by one), or
- A summary of material changes that includes an offer to provide a copy of the updated Part 2A (brochure) and instructions on how clients can obtain it.Within 120 days of its fiscal year-end, an adviser must deliver to each client either:
- Within 120 days of its fiscal year-end, an adviser must deliver to each client either:
- Compliance Best Practices
- Conduct an internal review well ahead of the filing deadline.
- Maintain detailed records of all changes and decisions leading up to the amendment.
- Consider a peer or compliance team review to ensure completeness and consistency.
| Assets Under Management | Annual Updating Amendment Fee |
| $100 million or more | $225 |
| $25 million to $100 million | $150 |
| Less than $25 million | $40 |
| Exempt Reporting Advisers | $150 |
December fiscal year-end advisers should consider the Form ADV amendment process not only as a regulatory requirement but also as an opportunity to strengthen internal compliance and client transparency. Timely and thorough filings help mitigate risk, maintain credibility with clients, and keep advisers in good standing with regulators.
Blueprint GRC can simplify the Form ADV amendment process for your firm. With nearly 10 years of IARD experience, we provide end-to-end support including Part 2A review and amendments, preparing Part 1A amendments, and submitting filings on your behalf, helping you stay compliant and confident throughout your year-end reporting.
