Delivery of ADV Part 2

On an annual basis, a registered investment adviser must (i) deliver within 120 days of the firm’s fiscal year end, to each Client a free updated Form ADV, Part 2A that either includes a summary of material changes or is accompanied by a summary of material changes, or (ii) deliver to each Client a summary of material changes that includes an offer to provide a copy of the updated Firm Brochure free of charge and information on how a Client may obtain it.

For those firms whose fiscal year ended 12/31, your delivery requirement is by April 30th.  If you have not already done so this year, this is also a good time to send out the firm’s Privacy Notice.

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