Missing Form ADV deadlines is one of the most avoidable compliance failures, and regulators treat it accordingly.
The Mistake
The two most common timing errors: filing the initial Form ADV late (missing the 60-day window after first close) and filing the annual amendment late (missing the 90-day window after fiscal year end).
Why It Happens
Fund managers are focused on closing investors, deploying capital, and managing portfolio companies. Form ADV deadlines do not have the same urgency as a deal closing, and they slip. The 60-day deadline for the initial filing sometimes catches managers who did not have their IARD account set up in advance.
The Fix
Calendar both deadlines immediately. For the initial filing, begin IARD setup and Form ADV preparation before your first close, not after. For the annual amendment, start gathering updated information (AUM, Schedule D data, ownership changes) at least 30 days before your fiscal year end.
How Capital Company Helps
Capital Company prepares and files Form D, blue sky filings, and Form ADV for funds on the platform. Schedule a demo to learn more.
This article is for informational purposes only and does not constitute legal advice. Consult qualified legal counsel for advice specific to your situation.