SKILL.md
Regulatory Reporting
Regulatory status current as of June 2026 — verify effective dates, dollar thresholds, and pending rulemakings against current SEC/FINRA/FinCEN sources before advising.
Core Concepts
Form ADV Amendments
Registered investment advisers must keep Form ADV current through two amendment mechanisms:
Annual updating amendment — Must be filed within 90 days of the adviser's fiscal year end (Rule 204-1 under the Investment Advisers Act of 1940). The annual amendment requires the adviser to review and update all items on Form ADV Parts 1, 2A, and 2B. The adviser must also deliver or offer to deliver the updated brochure (Part 2A) to existing clients within 120 days of fiscal year end, along with a summary of material changes.
Other-than-annual amendments (interim/prompt amendments) — Certain items on Form ADV must be amended promptly when information becomes inaccurate. "Promptly" is generally interpreted as within 30 days of the event, though some changes require faster action. Items requiring prompt amendment include:
- Changes in the adviser's organizational structure, control persons, or ownership (Part 1, Items 1, 2, 3, 7, 10, 11)
- Changes in disciplinary history (Part 1, Item 11, DRPs)
- Changes in the adviser's financial condition that would require disclosure under Part 2A Item 18
- Changes to the brochure (Part 2A) that are material and that clients or prospective clients should know about — including changes to types of advisory services, fee schedules, methods of analysis, risk factors, material conflicts, disciplinary events, or financial condition
Items that may wait for the annual amendment — Statistical information (AUM, number of clients), non-material updates to biographical information, and administrative details that do not affect client decision-making.