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RIA Regulatory Filings Policy Template

Advisers Act Sections 203 and 204, and the Exchange Act reporting rules

Every filing the firm may owe, when each is due, and who owns it, from Form ADV to beneficial ownership, Form PF, Form D and state notice filings.

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What the rule requires

An SEC-registered adviser files an annual updating amendment to Form ADV within 90 days after its fiscal year end, and amends promptly when certain information becomes inaccurate. Depending on what it does, it may also owe Schedules 13D or 13G, Form 13F, Form 13H, Form PF, Form D and state notice filings.

Each has its own threshold and deadline, and a missed filing is among the most common and most avoidable examination findings.

What the policy covers

The sections of Luna's model Regulatory Filings and Disclosures policy. Your draft includes only the clauses that apply to your firm.

  1. 1Purpose and ownership
  2. 2Disclosure of financial condition and disciplinary events
  3. 3Advisory and subscription agreements
  4. 4Form ADV
  5. 5Beneficial ownership reporting: Schedules 13D and 13G
  6. 6Form 13F and Form N-PX
  7. 7Form SHO (short positions)
  8. 8Form 13H (large traders)
  9. 9Section 16 and Rule 144
  10. 10Foreign filings
  11. 11State filings for the adviser
  12. 12Form D and state securities (blue sky) filings
  13. 13Form PF
  14. 14Other federal filings
  15. 15Records

What Luna asks you

A few of the questions that shape the draft:

  • Whether the firm files Form 13F or Form PF
  • Whether it takes positions above the beneficial ownership thresholds
  • Which exemption its fund offerings rely on
  • Who owns each filing

How drafting works

  1. 01
    Answer questions about your firm

    Plain questions about how you operate. Where there is a common answer, Luna suggests it; where you are not sure, say so and it is flagged rather than assumed.

  2. 02
    Luna drafts the policy

    Only the clauses that apply to your firm, in your firm's name, each traced to the rule or choice it comes from.

  3. 03
    Review what is left

    Anything unanswered is marked in the text and listed for you, and the policy cannot be approved until each is settled.

  4. 04
    Edit, approve and roll out

    It is your policy: edit it like any other, approve it, and have employees acknowledge it in the same place.

Read the source

Other policies

A summary of what the rule requires, current as of October 2026, so you can see what the policy covers. It is not legal advice. A policy drafted in Luna is your firm's draft to review, edit and adopt.