Reminder for all Registered Investment Advisers that had material changes to your ADV Part 2 (brochure) during the annual updating amendment – your ADV Part 2 must be delivered to all clients no later than April 30th (assuming a 12/31 year end).
SEC registered investment advisers must deliver to each client a free updated brochure that either includes a summary of material changes OR deliver to each client a summary of the material changes that includes an offer to provide a copy of the updated brochure and information on how a client may obtain the brochure.
State registered investment advisers should consult with their individual state to determine what their delivery requirement. For example, Texas and Washington require that the entire brochure be delivered annually whether there is a material change or not.
In both cases, however, the delivery requirement is the same – 120 days from the end of their fiscal year.