Form ADV Drafting & Annual Updates
Protect your firm’s regulatory standing with precise SEC disclosures, proactive annual updates, and off-cycle amendments tailored for RIAs and ERAs.
PUBLIC DISCLOSURE
The Core of Your Regulatory Identity
For both Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs), Form ADV is a key regulatory filing and an important public disclosure document. Investors, counterparties, and regulators may look to it to understand your business, fees, conflicts, and disciplinary history. Inconsistencies between Form ADV and other disclosures, or missed update deadlines, can create avoidable regulator questions and compliance risk.
At Ishimbayev Law Firm, we help translate Form ADV requirements into disclosures that are clear, careful, and aligned with how the firm actually operates. We also help reduce the administrative burden on internal compliance personnel by supporting drafting, updates, and filing coordination.
Services
Our Form ADV Services Include:
Initial ADV Drafting:
Preparing the initial filing package for new registrants, including Part 1A, Part 2A, Part 2B, and Form CRS where applicable.
Annual Updating Amendments:
Managing your critical 90-day post-fiscal-year-end filing deadline, calculating updated regulatory Assets Under Management (RAUM), and revising your brochure’s “Material Changes” summary.
Other-Than-Annual Amendments:
Filing prompt, off-cycle updates required by the SEC when material changes occur, such as changes in ownership, new disciplinary events, or the launch of a new fund strategy.
PPM & Marketing Consistency Reviews:
Reviewing Form ADV disclosures against offering documents and marketing materials to identify inconsistencies and disclosure gaps.
Our Approach
Our Approach to Form ADV Compliance
Operational Deep-Dive:
We interview your management team to capture the nuances of your current fee structures, related-party transactions, and soft-dollar arrangements.
Precision Drafting & IARD Management:
We translate complex business practices into plain-English disclosures required by the SEC, managing the entire data entry process within the IARD system.
CCO Review & Execution:
We provide a redlined review copy to your compliance team, explain the strategic reasoning behind our disclosure phrasing, and execute the final submission upon your approval.
why choose us
Why Partner with Ishimbayev Law Firm?
Clear Narrative Across Parts 1 and 2
The SEC can compare the data in Part 1 with the narrative in Part 2A. We work to align those sections and reduce inconsistencies that may invite follow-up questions in an exam or review.
Unburdening Your CCO
Managing the IARD system and deciphering the SEC’s convoluted Form ADV instructions is a massive drain on your team’s time. We handle the heavy administrative lifting so your internal team can focus on actual risk management and portfolio growth.
Dynamic Lifecycle Tracking
Your firm is not static. As you launch new funds, change fee structures, or onboard new executives, we help think through whether those events may require off-cycle amendments or related disclosure updates.
Plain English Precision
The SEC requires Part 2A to be written in plain English. We aim for disclosures that are readable and appropriately careful, while still reflecting the firm’s actual risks, conflicts, and business practices.
FAQ
Frequently Asked Questions
When is the Annual Updating Amendment due?
Both RIAs and ERAs must file an Annual Updating Amendment to their Form ADV within 90 days after the end of their fiscal year. For most firms with a December 31 fiscal year-end, the deadline falls at the end of March.
What is the difference between Part 1 and Part 2 of Form ADV?
Part 1 is a fill-in-the-blank, check-the-box format that provides the SEC with structured data about your firm’s size, ownership, clients, and disciplinary history. Part 2 (the Brochure) is a narrative document written in plain English that explains your business practices, fees, and conflicts of interest directly to your clients and investors.
Do Exempt Reporting Advisers (ERAs) have to file a Form ADV?
Yes. While ERAs are exempt from full SEC registration, they are still required to complete and file specific sections of Form ADV Part 1A through the IARD system and must update it at least annually.
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