Investment Adviser Registration, Form ADV, and Regulatory Filing Support
Practical Filing and Disclosure Support From Former SEC Examiners and Exam Managers
ClearView assists investment advisers with registration, Form ADV filings and amendments, regulatory disclosures, and related filing responsibilities. Our former SEC examiners and exam managers help firms prepare filings and disclosures that accurately reflect the adviser’s business and are consistent with its policies, agreements, and actual practices.
Registration and Filing Support That Reflects the Firm
Regulatory filings are more than administrative forms. Form ADV and related disclosures describe important aspects of the adviser’s business, services, fees, conflicts, ownership, clients, affiliations, and other activities. Those disclosures should accurately reflect how the firm actually operates and should be consistent with related policies, agreements, and client communications.
ClearView approaches registration and filing work from a compliance perspective. We help firms gather relevant information, prepare or update filings, identify potential inconsistencies, and consider whether changes in the business should also be reflected elsewhere in the compliance program.
When Registration or Form ADV Support May Be Useful
Common circumstances that may warrant registration or Form ADV support include the following.
Starting a New Advisory Firm
Assist with preparing applicable registration filings and disclosures within the agreed scope of the engagement.
Annual Form ADV Updates
Assist with the annual Form ADV updating process, including reviewing business changes, disclosures, filing information, and consistency across applicable parts of Form ADV.
Material Business Changes
Evaluate filing and disclosure updates associated with changes in services, fees, ownership, personnel, investment strategies, conflicts, clients, affiliations, or other aspects of the adviser’s business.
Interim Form ADV Amendments
Assist with amendments between annual updating filings when changes in the adviser’s business or disclosures require or warrant updates to applicable Form ADV information.
New or Revised Disclosures
Assist with updates to regulatory disclosures when the firm introduces new business practices, relationships, conflicts, services, or other matters requiring disclosure consideration.
Registration or Filing Projects
Provide additional compliance resources for registration, filing remediation, disclosure updates, or other Form ADV-related projects when internal personnel need assistance.
Areas We May Support
The applicable filings and scope depend on the adviser’s business, registration status, regulatory requirements, and engagement.
Form ADV Part 1
Assist with preparation and updating of applicable Form ADV Part 1 information concerning the adviser’s business, ownership, clients, regulatory status, assets, affiliations, disciplinary information, and other required information.
Form ADV Part 2A Brochure
Develop, review, or update the adviser’s brochure to reflect its advisory services, fees, conflicts, business practices, disciplinary information, and other applicable disclosures.
Form ADV Part 2B Brochure Supplements
Assist with preparation and updating of applicable brochure supplements for supervised persons, including related disclosure and delivery considerations.
Form CRS (Relationship Summary)
Where applicable, assist with preparation or updating of the firm’s relationship summary and related disclosure and filing considerations.
Annual Updating Amendments
Support the annual Form ADV updating process, including gathering relevant changes, reviewing disclosures, preparing amendments, and identifying related compliance updates that may warrant consideration.
Other-Than-Annual Amendments
Assist with interim amendments when changes in the adviser’s business or disclosures require or warrant updates to applicable Form ADV information.
IARD Filing Coordination
Assist with IARD-related filing preparation and coordination, including filing-ready materials and, where authorized and within the engagement scope, electronic filing assistance.
Related Regulatory Filings and Disclosures
Assist with related investment adviser regulatory filings, notice filings, disclosure updates, and other filing responsibilities within the agreed engagement scope. State registration or notice filing support depends on the applicable jurisdiction and engagement scope.
The filings and disclosures applicable to a particular adviser depend on its registration status, business activities, applicable jurisdiction, regulatory requirements, and the agreed scope of the engagement.
More Than Completing a Form
A filing may be technically complete while still creating compliance risk if it does not accurately describe how the adviser operates. ClearView focuses not only on preparing the applicable filing, but also on identifying inconsistencies among regulatory disclosures, client communications, policies and procedures, agreements, and actual business practices.
This broader compliance perspective can be particularly important when a firm has grown, changed services, revised fees, added affiliates, introduced new investment strategies, changed personnel, or otherwise evolved since its disclosures were last comprehensively reviewed.
How ClearView Approaches a Registration or Form ADV Engagement
The scope of each engagement is tailored to the firm, but a ClearView registration or Form ADV engagement generally follows a structured process.
Understand the Firm
Develop an understanding of the adviser’s ownership, personnel, services, clients, investment activities, fees, conflicts, affiliations, operational structure, and existing disclosures.
Identify the Filing Scope
Identify the filings, amendments, disclosures, and supporting information included within the agreed scope of the engagement.
Prepare and Review the Filing
Prepare or update applicable Form ADV materials and evaluate the information for completeness, consistency, and alignment with the adviser’s actual business practices.
Reconcile Related Disclosures
Identify potential inconsistencies among Form ADV, client disclosures, agreements, policies and procedures, marketing materials, and other relevant information within the engagement scope.
Finalize and Support Filing
Work with the firm to resolve open items, finalize filing-ready materials, and provide filing assistance where authorized and included in the engagement.
Form ADV and the Broader Compliance Program
Form ADV should not be viewed in isolation from the adviser’s compliance program. Changes disclosed in regulatory filings may also affect policies and procedures, compliance testing, marketing materials, client agreements, conflicts management, or other aspects of the firm’s compliance framework.
ClearView can help identify those connections so that significant business changes are addressed consistently across the firm’s regulatory disclosures and compliance program. For related support, see ClearView’s policies and procedures development and ongoing compliance support services.
Former SEC Examination Experience
ClearView’s team includes former SEC examiners and exam managers with decades of experience conducting, supervising, and managing examinations of investment advisers and reviewing adviser regulatory filings and disclosures.
That experience provides a practical understanding of how Form ADV and related disclosures may be evaluated during an examination, including whether disclosures are internally consistent and aligned with the adviser’s actual practices.
Related ClearView Services
ClearView offers a range of complementary compliance services for registered investment advisers.
Policies and Procedures Development
Development and enhancement of compliance policies and procedures tailored to the adviser’s business activities, regulatory obligations, and compliance risks.
Learn moreOngoing Compliance Support
Ongoing compliance assistance for RIAs, including testing, filings, policy updates, remediation, and support for the firm’s compliance function.
Learn moreAnnual Compliance Reviews
Risk-based annual compliance reviews designed to identify compliance risks, gaps, and remediation priorities.
Learn moreMock SEC Examinations
Test the firm’s compliance program, disclosures, controls, and practices before an actual SEC examination.
Learn moreSEC Examination Support
Support during an actual SEC examination, including document production, interviews, responses, potential findings, and remediation.
Learn moreMarketing Rule & Advertising Reviews
Independent review of advertisements, performance presentations, testimonials, endorsements, third-party ratings, and related Marketing Rule compliance practices.
Learn moreNeed Help With Registration or Form ADV?
Talk with a former SEC examiner or exam manager about your firm’s registration, Form ADV amendments, regulatory disclosures, or other investment adviser filing needs.