You Filed Your ADV Annual Amendment – What’s Next?

The March 31 deadline for the annual Form ADV updating amendment has finally passed for advisers with a December 31 fiscal year end. Filing the amendment is only step one. April is the month to turn attention to what comes next: delivering or offering required documents to clients, confirming your records are in order, and keeping an eye on Q2 filing obligations.

The Annual Offer/Delivery Obligation

RIAs are required to deliver or offer certain documents to their clients by April 30.

RIAs with a December 31 fiscal year end have 120 days after year-end – until April 30, 2026 – to satisfy their annual delivery or offer obligation to existing clients. As part of this obligation, advisers must deliver:

1. A current copy of the updated Form ADV Part 2A brochure that includes a summary of material changes, or
2. A summary of material changes only, with an offer to provide the full updated brochure upon request, including the adviser’s website, email address, phone number, and the IAPD website address where clients can access the brochure.

Delivery may be made electronically – by email with a PDF attachment, or a link to the brochure on the adviser’s public website – or by physical mail, as long as the adviser has obtained appropriate client consent for electronic delivery.

What to Send in April

As part of the annual offer/delivery, advisers should deliver the following documents:

1. Form CRS (Client Relationship Summary)

Advisers serving retail investors must maintain a current Form CRS. Following the ADV amendment, advisers should confirm that their Form CRS is current and reflects any material changes to the firm’s services or fee structures. When delivering Form CRS as part of a package of documents, Form CRS must appear first in the package. Advisers must also include a copy of Form CRS conspicuously on their website and upload an updated copy after each amendment.

2. Form ADV Part 2A (the “Brochure”)

The Brochure, or the summary of changes with the offer to deliver the full brochure, must reach all existing advisory clients by April 30, 2026.

3. Form ADV Part 2B (the “Brochure Supplement”)

While the Brochure Supplement is not required to be delivered annually to existing clients as a rule, many firms deliver updated supplements to all clients annually as a best practice, in addition to regular delivery at specific times. Advisers who choose to deliver their 2B as part of the annual letter should document their policy and apply it consistently.

4. Privacy Notice

Advisers are generally required to deliver an annual privacy notice to clients. The notice can be delivered as part of the annual letter.

Recordkeeping and documentation is a critical SEC examination priority.

Delivery records are a routine focus area in SEC examinations. Advisers should maintain records that include the date sent, delivery method, and client list for each delivery cycle.

Q2 Reminders: Form 13F and Form 13H

Mark these on the calendar now.

For firms with reporting obligations under Section 13 of the Securities Exchange Act of 1934, the following deadlines are approaching:

Form 13F – Institutional Investment Managers

Advisers with 13F filing obligations must file Form 13F quarterly.

• Q1 2026 (March 31 quarter-end): due May 15, 2026
• Q2 2026 (June 30 quarter-end): due August 14, 2026

Form 13H – Large Traders

Large traders must file Form 13H. The annual Form 13H-A for calendar year 2025 was due February 17, 2026.

Quarterly amended filings (Form 13H-Q) must be filed promptly following the end of any calendar quarter in which any information in the most recent Form 13H becomes inaccurate. Applicable filers should confirm whether the Q1 2026 (March 31 quarter-end) amendment is required and file promptly.

Put April 30 on your Compliance Calendar.

The annual ADV filing is done, but the compliance work continues. Advisers should confirm whether material changes trigger delivery obligations, get documents out to clients before April 30, and document every step of the process. Recordkeeping around delivery is straightforward to implement and highly visible to examiners – there is little reason to leave gaps.

Advisers with questions about their specific delivery obligations, what qualifies as a material change, or how to structure their annual client outreach can contact their attorney or paralegal at Stark & Stark for assistance, or directly contact Joseph C. Antonakakis at jantonakakis@stark-stark.com.