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Template

Form ADV Annual-Amendment Data Refresh Template

Published May 10, 2026

Form ADV annual amendments require the firm to update every part that has changed and attest to the rest. The mistake firms make isn't filing late — it's filing without a structured trail of what changed. This template ships a populated workbook structure that captures the change log, the attesting individual, and the filing record per part.

What you walk away with

~18 min · 7 slots · 19 blocks
  • A pre-structured change log per Form ADV part (1A, 2A, 2B, 3 / CRS).
  • An attestation block naming the individual responsible for each part.
  • A filing record block tying the amendment to its IARD submission and post-filing review.
  • An artifact compliance can hand the SEC examiner the moment they ask 'what changed in the last amendment?'
0 / 7 filled0%

Variables

Live document preview

Form ADV Annual Amendment — [FIRM_NAME] ([CRD_NUMBER])

Fiscal year: [FISCAL_YEAR] · Filing deadline: [FILING_DEADLINE] · Target filing date: [AMENDMENT_FILING_DATE_TARGET_]

CCO: [CHIEF_COMPLIANCE_OFFICER] · Preparer: [PREPARER_NAME]

1. Part 1A — change log

What goes hereguidance — delete before sending

List every Item in Part 1A that changed since the last amendment. Even when 'nothing changed,' note that explicitly per item — the absence of a no-change attestation is a finding pattern.

  • Item 5 (Information About Your Advisory Business): [CHANGES_OR_NO_CHANGE]
  • Item 5.K (Wrap-Fee Programs): [CHANGES_OR_NO_CHANGE]
  • Item 7 (Financial Industry Affiliations): [CHANGES_OR_NO_CHANGE]
  • Item 8 (Participation or Interest in Client Transactions): [CHANGES_OR_NO_CHANGE]
  • Item 9 (Custody): [CHANGES_OR_NO_CHANGE]
  • Item 11 (Disclosure Information): [CHANGES_OR_NO_CHANGE]
  • Item 1 / 2 (Identifying / Other Identifying): [CHANGES_OR_NO_CHANGE]
  • AUM as of fiscal year end: $[AUM_AS_OF_YEAR_END]
  • Number of clients: [CLIENT_COUNT]
  • Number of accounts: [ACCOUNT_COUNT]

2. Part 2A — brochure refresh

  • Item 4 (Advisory Business): [CHANGES_OR_NO_CHANGE]
  • Item 5 (Fees and Compensation): [CHANGES_OR_NO_CHANGE]
  • Item 6 (Performance-Based Fees and Side-by-Side Management): [CHANGES_OR_NO_CHANGE]
  • Item 8 (Methods of Analysis, Investment Strategies and Risk of Loss): [CHANGES_OR_NO_CHANGE]
  • Item 10 (Other Financial Industry Activities and Affiliations): [CHANGES_OR_NO_CHANGE]
  • Item 11 (Code of Ethics, Participation in Client Transactions and Personal Trading): [CHANGES_OR_NO_CHANGE]
  • Item 14 (Client Referrals and Other Compensation): [CHANGES_OR_NO_CHANGE]
Marketing Rule alignmentguidance — delete before sending

Re-verify Item 6 + Item 14 against the post-2021 Marketing Rule (Rule 206(4)-1). Performance presentation, testimonials, and endorsements have changed structurally; brochures that haven't been refreshed since 2021 likely need updating.

3. Part 2B — brochure supplements

What goes hereguidance — delete before sending

List every individual subject to a Part 2B supplement. For each, attest: education / business background current, disclosures current, signed by the individual.

  • Total individuals requiring 2B: [COUNT]
  • Supplements current: [COUNT_CURRENT] / [COUNT_TOTAL]
  • New supplements added during the year: [LIST]
  • Supplements removed (terminations / role change): [LIST]

4. Part 3 — Form CRS

  • CRS current version: [CRS_VERSION]
  • CRS reconciles to Part 1A and Part 2A: [YES_NO_PARTIAL]
  • Initial CRS delivery logged for every retail relationship: [YES_NO_PARTIAL]
  • Re-delivery on material change logged: [YES_NO_PARTIAL]

5. Attestations

Preparer
[NAME]
Signature / date
Chief Compliance Officer
[NAME]
Signature / date
CEO / Managing Member
[NAME]
Signature / date

6. IARD filing record

  • IARD filing id: [FILING_ID_FROM_IARD]
  • Filing date: [AMENDMENT_FILING_DATE_TARGET_]
  • Filing acknowledgment received: [DATE]
  • Post-filing internal review completed: [DATE]

Unfilled slots show as [VARIABLE_NAME] so the partial document still reads. Filling in the form on the left substitutes them inline.

What to do with this

Use as the working document for the annual amendment cycle. The preparer fills it in over the 60 days before the filing window. CCO reviews and signs. File the populated document alongside the IARD submission record. Examiners ask for this; firms that have it sail through the 'what changed' question.

ChecklistForm ADV Annual Amendment ChecklistAssessmentForm ADV Disclosure Completeness Scorecard
Calibrated against: Form ADV General Instructions + IARD validation rules + SEC Division of Examinations risk alertsCalibrated against the SEC's Form ADV General Instructions, the IARD-system validation framework, and SEC Division of Examinations risk alerts on Form ADV deficiencies 2022-2025.

FAQ

Does this replace the IARD filing?

No. This is the working document the firm uses to assemble and attest to the IARD filing. The IARD filing itself is the regulatory submission; this template is the audit trail of how the firm got there.

Should we file this with the SEC?

No — it's an internal working document. Examiners will ask to see it during routine examinations, but it's not part of the public IARD submission.

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