Practice question, Disclosure documents and filings
Reconcile your current Form ADV against your actual fees, affiliates, client base and services, and show when the last annual updating amendment and any other-than-annual amendments were filed.
Taft practice question: not an official regulator question. SEC Division of Examinations, United States (federal). For SEC-registered investment advisers. Evidence category: Filings.
Not legal advice. A practice prompt for rehearsing how your team explains its controls and evidence. No scoring, no model answer, no implication that a regulator will ask these words.
Authored by Taft. Last checked 2026-11-09. All questions.
Why it is relevant
Staff observed disclosure documents with omissions or inaccurate information and untimely filings, with the omissions related to fees and compensation, business or operations, and services offered to clients.
Sources: [1] Staff Observations, Disclosure Documents and Filings
Evidence to locate
Suggested, not mandatory. A regulator's actual request list governs.
No evidence cues listed.
Follow-up prompts
Who signs off on each amendment, and what triggers an interim amendment at your firm?
Applicability
- Applies to
- Advisers registered or required to be registered with the SEC. The annual updating amendment timing is a deadline reference in this toolkit.
- Does not apply to
- Not stated.
Cite
Cite the official source first. Then: Taft Compliance Group, Exam-prep toolkit (draft), question q-form-adv-accuracy, https://taftcompliance.com/resources/exam-prep-toolkit/questions/q-form-adv-accuracy, last checked 2026-11-09.
Sources
U.S. Securities and Exchange Commission, Division of Examinations, Risk Alert: Observations from Examinations of Newly-Registered Advisers (staff statement). regulator guidance. Staff Observations, Disclosure Documents and Filings, page 4.
https://www.sec.gov/files/risk-alert-newly-registered-ias-032723.pdf
Checked 2026-11-09; published 2023-03-27.
Supporting passage
The staff observed required disclosure documents that contained omissions or inaccurate information and untimely filings (i.e., material or annual form updates were not made within prescribed timeframes or at all). The disclosure omissions and inaccuracies were related to advisers': (1) fees and compensation; (2) business or operations (including affiliates, other relationships, number of clients, and assets under management); (3) services offered to clients, such as disclosure regarding advisers' investment strategy (including the use of models), aggregate trading, and account reviews;
Changes to this question
No released changes.