Advisers still seem a bit befuddled (what a great word) by the annual delivery requirements for their firm brochure (i.e., ADV Part 2A).
These are the possible scenarios:
- If there are no material changes, you can merely offer (in writing) to provide each client with a copy of your ADV 2A if they so desire.
- If, however, there are material changes, you can do one of two things:
- Provide clients with a Summary of Material Changes together with an offer to provide the entire document if they so desire; or
- Provide the entire document.
You do not need to provide the ADV 2B on an annual basis unless there are material changes to that document.