Form ADV Annual Updating Amendment
The Form ADV annual updating amendment is the once-a-year filing in which a registered investment adviser updates its entire Form ADV and affirms that the information in it is current. It is filed through IARD, and it is required even in a year when nothing about the firm changed.
- Who handles it
- Every SEC-registered and state-registered investment adviser, annually, regardless of whether anything changed.
- Filed through
- IARD
- Applies to
- SEC-registered RIA, State-registered RIA, Dually registered
What the form asks for
- Full review and update of every Part 1A item
- Updated regulatory assets under management as of fiscal year end
- Updated client counts and client-type breakdown
- Refreshed disciplinary and affiliation disclosures
- Updated Part 2A brochure and summary of material changes
- Updated Part 2B supplements for supervised persons
- Updated Form CRS where the relationship summary has changed
The work behind the filing
Assemble the year-end data pack
The amendment needs point-in-time figures as of fiscal year end pulled from systems that keep moving. Running that extraction late means reconstructing a date that has already passed. Caddi can capture the year-end snapshot on the date it matters and hold it with its provenance.
Produce the material-changes summary
The summary of material changes has to reflect what actually changed in the brochure, which means a real comparison against the last delivered version. Caddi can generate the underlying change set from the prior filing so the narrative is written against evidence rather than memory.
Run the annual attestation cycle
Outside business activities, political contributions, and personal securities disclosures come from people, not systems, and the chase is the slow part. Caddi can issue, track, escalate, and file the whole cycle.
Evidence the post-filing delivery
Filing is not the end. The updated brochure or the summary of material changes has to reach clients, and that delivery has to be evidenced per client. Caddi can drive the delivery from the CRM and retain proof against each client record.
Questions
Why is the annual amendment so much work when nothing has changed?
Because affirming that the form is current still means re-deriving everything in it. Assets under management and client counts have to be recomputed as of the reporting date, every answer has to be checked against last year's, and anything that moved needs an explanation. The workload comes from the verification, not the typing.
Do I have to file the annual updating amendment if nothing changed?
Yes. The annual updating amendment is required every year regardless of whether any information changed.
What happens after I file the annual amendment?
The filing itself does not satisfy the client-facing obligation. Depending on what changed, the updated brochure or a summary of material changes has to be delivered to clients, and that delivery has to be evidenced.
Does Caddi file this form for me?
No. Caddi does not submit filings to IARD, FINRA Gateway, EDGAR, or any regulator, and it is not a substitute for your compliance program or your CCO. Caddi automates the work around the filing: gathering the underlying data out of your portfolio, CRM, and document systems, reconciling it against the prior filing, flagging what changed, and evidencing delivery. A human still reviews and files.
Related forms
The filing is the easy part
Caddi does not file forms. It runs the work around them: pulling the underlying data out of your portfolio, CRM, and document systems, reconciling it against the prior filing, and evidencing delivery. See it run on your own stack.
See the compliance specialistThis page describes what the form is and the work it creates. For requirements, deadlines, and whether any of it applies to your firm, see SEC — Form ADV general instructions.