Form ADV Amendment Rule
Rule 204-1 · 17 CFR 275.204-1
Amendments to Form ADV
Read the current text at the source ↗Guide: Form ADV Annual Updating Amendment: Deadline, What to Update and Interim Amendments
Guide: How to Register as an RIA: SEC or State Registration, Form ADV and Timeline
Guide: Form ADV Part 2A and 2B: The Brochure and Brochure Supplements
Guide: Form CRS Requirements for Investment Advisers
- Applies to
- SEC-registered investment adviser
- Last amended
- September 10, 2019
What the rule says
A description of the source text.
Requires an adviser to amend Form ADV Parts 1 and 2 at least annually, within 90 days of the end of its fiscal year, and more frequently than that where the instructions to Form ADV require it. Part 3, the relationship summary, is amended at the frequency the instructions set. 84 FR 33630 (12 July 2019), with earlier amendments in the source note.
What it requires
Luna's plain-English reading, not the Commission's words.
- 01The rule sets a floor. What actually triggers an interim amendment lives in the Form ADV instructions, not here, and that is the part firms miss.
- 0290 days for the amendment, 120 days for the brochure delivery under Rule 204-3. Do not run them on one calendar entry.
- 03The annual updating amendment is the moment the firm's own answers about custody, discretion, AUM and disciplinary history are re-attested. Treat it as an annual review input, not a filing chore.
What examiners find
Luna's observations, not a Commission publication.
- Item 5 figures that no longer match the firm's own records.
- Interim-amendment triggers missed because nobody re-read the instructions.
Topics
Source last checked against the regulator's copy on October 14, 2026. That date is written by an automated check, not by hand.
Luna Compliance is software, not a law firm. This page is not legal advice and reading it creates no attorney-client relationship. Where this page and the regulator's copy differ, the regulator's governs.