Compliance Solutions for Investment Advisers

ADV 2A Delivery Requirements

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:

  1. 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.
  2. 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.

 

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