Promptly (the SEC generally expects within 30 days) whenever a material change occurs to the information in your Form ADV. You do not wait for the annual amendment to report these changes.
Common triggers for an other-than-annual amendment include:
- Change to your firm's legal name or principal office address
- Change in ownership or control persons (new partners, departing principals)
- New disciplinary events or legal proceedings
- Receipt of a previously pending audit report
- Change to your form of organization (e.g., converting from LLC to LP)
The most frequently missed trigger is a change in control persons. When you add a new managing member or general partner, that requires a prompt amendment, not just a note for your next annual filing. Failing to report material changes on time can result in your filing being flagged as inaccurate on IAPD.
See Form ADV for Private Fund Managers: The Complete ERA Filing Guide.
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