What is Form ADV? Definition, Requirements, and How to File

December 26, 2023 by Abi Tyas Tunggal

Form ADV is a critical regulatory filing that investment advisers use to register with the SEC and state securities authorities. It's a comprehensive document, providing a snapshot of an adviser's business, including their investment styles, assets under management, and key operational details. Advisers are required by law to update this form annually, and to amend it promptly if certain information changes. Prospective and current clients can access these filings to gain insight into the adviser's business practices and any potential conflicts of interest.

Investment advisers are obligated to disclose detailed information about their qualifications, investment strategies, and risk management practices on Form ADV. The form is divided into several parts; Part 1 contains basic information for regulatory bodies, Part 2 serves as a narrative brochure for clients, detailing the firm's services, fees, and strategies, and Part 3 provides additional clarity on the firm's conduct, including a roundup of disciplinary history if applicable. Understanding Form ADV is essential for clients seeking transparency and for advisers maintaining compliance and trustworthiness in their financial dealings.

Key Takeaways

  • Form ADV is used for registration with the SEC and state authorities, providing essential details about an investment adviser's business.
  • The document is divided into multiple parts, each offering specific information on the adviser's operations, strategies, and risk management.
  • Transparency and regulatory compliance are key aspects highlighted in Form ADV, aiding clients in making informed decisions.

Form ADV Overview

Form ADV is a regulatory filing that investment advisers must submit to the Securities and Exchange Commission (SEC) and state securities authorities. It is essential for compliance and transparency within the investment advisory industry.

Purpose and Requirement

Form ADV serves a dual function as both a registration document and a disclosure document for investment advisers. It is required by the SEC and state securities authorities for advisers managing $25 million or more in client assets. The submission of Form ADV ensures an adviser is legally authorized to provide investment advice and also offers a layer of transparency to the public, who can access parts of the form online.

Components of Form ADV

Form ADV consists of two main parts:

  • Part 1: This section requires information about the adviser's business, ownership, clients, employees, and disciplinary events, if any. It is filled in a structured, check-the-box format with corresponding schedules.
  • Part 2: Often referred to as the "brochure," this part is narrative in style and includes detailed information about the adviser's services, fees, investment strategies, risks, and disciplinary information.

These components collectively provide regulators and potential clients a comprehensive view of an adviser's qualifications, operational methods, and history.

Part 1 of Form ADV

Part 1 of Form ADV requires detailed disclosures concerning an investment adviser’s business, ownership, clients, and employees, as well as disciplinary events, if any. This provides a comprehensive profile of the adviser's operations to the SEC and assists clients in evaluating potential advisers.

Identifying Information

An investment adviser must submit accurate identifying information, which includes name, number of employees, location, and contact details. This serves as a foundational reference that establishes the identity of the firm within the regulatory framework.

Business Model and Ownership

The firm must disclose its business model including types of services offered. The section covers the adviser's business practices and affiliations, and provides a detailed account of ownership structure, listing principal owners and those with a controlling interest.

Clients and Employees

A clear outline of the adviser's clientele types and employee count is required in this section. It assists in understanding the scale of the adviser's business and the scope of their operations. Information provided includes:

  • Clients: Types (individuals, businesses, etc.) and approximate number
  • Employees: Number of staff and description of their roles within the firm

Disciplinary Information

Any legal or disciplinary events involving the firm or its employees that are material to a client’s evaluation of the firm or the integrity of its management must be reported. This includes:

  • Disciplinary Events: Historical and pending incidents
  • Legal Events: Civil, criminal, regulatory, or administrative proceedings

The disclosure of disciplinary information is a crucial aspect as it maintains transparency and integrity within the financial market, aiding clients in making informed decisions.

Part 2 of Form ADV

Part 2 of Form ADV mandates that investment advisers provide a written disclosure brochure and brochure supplements to their clients. This section serves as the main source of information regarding an adviser’s practices, fees, and conflicts of interest.

Brochure

The brochure (Part 2A of Form ADV) is a document designed in plain English to clearly outline an investment adviser's business practices, management style, fees, possible conflicts of interest, and other essential information for clients. It is established as a narrative format to make it comprehensible and must be delivered to the advisory clients.

Brochure Supplements

Brochure supplements (Part 2B of Form ADV) offer additional information about certain supervised persons of an adviser. They typically provide background on the educational and business experience of the adviser’s personnel whom clients may rely upon for investment advice.

Summary of Material Changes

Investment advisers are required to prepare a "Summary of Material Changes" if there have been any substantial alterations to the brochure from the previous year. This summary aids clients in identifying significant amendments that may impact their advisory relationship. It should be attached to the brochure as its first item, or if not included within the brochure, advisers must communicate the material changes to their clients.

Part 3 of Form ADV

Part 3 of Form ADV, also known as the Relationship Summary, is a critical disclosure document required by the SEC. Focused on transparency, it aims to inform retail investors about the key aspects of their relationship with investment advisers.

Relationship Summary

The Relationship Summary section of Form ADV Part 3 provides retail investors with succinct and relevant information about an investment adviser's services. Investment advisers are mandated to clarify their types of services, fees, and any potential conflicts of interest. Furthermore, this part highlights the required standard of conduct for advisers, ensuring investors are aware of the level of care the adviser must adhere to when providing guidance.

One of the central elements of the Relationship Summary is the key questions section. This is designed to help retail investors assess the information being provided. It prompts them to ask insightful questions such as:

  • What are the main fees and costs that I will pay if I invest with you?
  • What services can I expect to receive for those fees?
  • How might your conflicts of interest affect me, and how will you address them?
  • How do you and your financial professionals make money?

These questions facilitate deeper engagement between investors and their advisers, and encourage a more thorough understanding of the investment relationship. Investment advisory firms subject to Form CRS/Form ADV Part 3 are required to diligently complete these sections, maintaining accuracy and clear communication at all times.

Advisory Business Practices

In the realm of investment advice, transparency about business practices is crucial for client trust. This section details the primary ways advisers structure their business in terms of services, fees, and compensation.

Fees and Compensation

Investment advisers typically outline their fee schedules in Form ADV Part 2A. Advisers may charge fees in various formats:

  • Hourly rates: Based on the actual time advisers spend on services.
  • Fixed fees: Agreed upon flat rates for specific services.
  • Asset-based fees: Calculated as a percentage of assets under management, payable quarterly or annually.

These fees are often negotiable depending on the client's investment portfolio size and the complexity of the services required.

Advisory Services Offered

Advisory services listed in Form ADV may include:

  • Portfolio management: Tailoring investment strategies to individual client needs.
  • Financial planning: Providing personalized recommendations and action plans for clients’ financial goals.
  • Pension consulting: Assisting pension and other institutional clients with portfolio composition and risk assessment.

They must thoroughly describe these services, ensuring clients have adequate information to make informed decisions.

Performance and Fee Structure

Some investment advisers may offer performance-based fees as an incentive for achieving specific benchmarks. This structure must align with regulations to ensure that performance-based fees are fair and that clients understand their potential obligations should the adviser's performance meet the agreed criteria.

It is vital for advisers to clearly articulate their performance-based fee structures to avoid any misunderstandings about how fees are calculated and charged.

Risk Management and Strategy

Form ADV Part 2A requires investment advisers to provide clear disclosure of their risk management policies and investment strategies. This section examines the methods used to analyze investments and outlines the required disclosures on risks associated with such investment strategies.

Investment Strategies and Analysis

Investment advisers detail their investment strategies and methods of analysis within Form ADV. They meticulously describe each strategy they intend to use, which may include equity, fixed income, international securities, or more complex vehicles like derivatives. The strategies are aligned with the client's risk profile and investment objectives. The methods of analysis refer to the tools and processes used to evaluate the performance and risk of the investment vehicles such as fundamental analysis, technical analysis, or quantitative analysis. Each method has its strengths and plays a crucial role in establishing the investment strategy.

Risk Disclosure

Advisers are required to openly communicate the risks associated with their investment strategies in Form ADV Part 2A. Risk disclosures are crucial for prospective and current clients to understand the potential downfalls related to the invested assets. These risks may include market risk, liquidity risk, credit risk, and others specific to investment strategies. For instance, a strategy that involves derivatives would disclose the inherent leverage, market, and counterparty risks. Investment advisers are expected to present these risk disclosures clearly, allowing clients to make informed decisions based on a thorough understanding of potential investment risks.

Regulatory Compliance and Disclosures

The section addresses integral aspects of Form ADV, which investment advisers use to meet regulatory compliance and execute mandatory disclosures. It delineates the rigidity of the filing requirements, embodied ethics, and potential consequences of non-compliance.

Regulatory Filings and Updates

Form ADV serves as a principal document for investment advisers to register with the SEC and state securities authorities. Advisers are required to file amendments to Form ADV both annually and promptly upon certain changes in their information. These amendments serve as critical updates that reflect the current state and operations of the firm to both regulators and the public.

  • Amendments are required for changes such as:
  • Contact information
  • Regulatory assets under management
  • Disciplinary information

Standard of Conduct and Ethics

Investment advisers adhere to a fiduciary standard which mandates actions in the best interest of their clients. The code of ethics outlines principles of honesty, integrity, and professionalism that advisers must follow. Disclosures related to this conduct provide insight into the adviser's alignment with fiduciary responsibilities and ethical standards.

  • Key ethics disclosures include:
  • Personal securities transactions
  • Conflicts of interest
  • Insider trading policies

Disciplinary Actions

Disclosures regarding any disciplinary actions are pivotal as they impact the adviser’s credibility and regulatory standing. Negative disclosures can include a history of violations, regulatory sanctions, or other legal impediments that directly affect the adviser's regulatory compliance.

  • Disciplinary information may involve:
  • SEC sanctions
  • Civil judicial actions
  • Criminal convictions

Background Information

In the pursuit of transparency and informed decision-making, Form ADV serves as a crucial touchstone for revealing a financial advisor's qualifications and educational background. It is a regulatory filing that investment advisors must submit to the Securities and Exchange Commission (SEC) and state securities authorities.

Financial Advisor Qualifications

Form ADV requires that investment advisors disclose detailed professional qualifications. This mandatory documentation includes a comprehensive summary of the advisor's:

  • Employment History: details of past and current positions, emphasizing responsibilities and duration at each role.
  • Industry Experience: a chronological account of the advisor's relevant financial sector involvement.

Education and Certifications

Investment advisors must also provide a record of their educational background, which encompasses:

  • Degrees: institutions attended, degrees obtained, and fields of study.
  • Certifications and Designations: professional certifications like the Certified Financial Planner (CFP) or Chartered Financial Analyst (CFA), including the granting organizations and status of such credentials.

This information is integral to assessing an advisor's expertise and authority in providing financial guidance.

Client Communications and Reporting

Investment advisers are required to provide clear and concise reports to their clients, primarily through narrative brochures. These documents, prepared in plain English, are essential for maintaining transparency and comprehensibility in adviser-client communications.

Brochures and Narrative Disclosures

Narrative Brochures: Advisers must create and distribute a narrative brochure written in plain English that facilitates easy understanding. They present essential details about the advisory firm that are crucial for clients and prospective clients.

  • Content Requirements:Services Offered: A detailed description of the services provided.
  • Fees and Compensation: Clear explanation of the fee structure and compensation methods.
  • Disciplinary Information: Any legal or disciplinary events that are material to a client’s evaluation of the advisory business or the integrity of the management personnel.
  • Conflict of Interest: Information on practices that may affect the adviser’s objectivity.
  • Investment Strategies: An overview of the investment strategies and risk of loss involved.

Plain English Disclosures: These disclosures are part of the narrative brochure and are designed to be straightforward, avoiding technical jargon. They aim to provide clients with a clear understanding of the services they are receiving and any associated risks, fees, or potential conflicts of interest.

  • Delivery to Clients:Narrative brochures must be delivered to advisory clients at least once a year and promptly when material changes occur.
  • New clients must receive the brochure before or at the time of entering into an advisory contract.

Investment advisers have the obligation to keep clients informed and ensure the integrity of communications through the use of narrative brochures and plain English disclosures.

Additional Information

Form ADV is a regulatory filing that investment advisors must submit to the SEC and state securities authorities. It contains essential details about the advisor's business, practices, and conflicts of interest. Investors can access this public record through a specific platform designed to increase transparency.

Investment Adviser Public Disclosure

The Investment Adviser Public Disclosure (IAPD) website is a resource where information filed on Form ADV is made available to the public. Potential and current clients can verify an advisor's credentials and disciplinary history.

  • Website Accessibility: The IAPD website is freely accessible to anyone seeking information about registered investment advisors.
  • Public Record Availability: Form ADVs filed by investment advisors are part of the public record and can be viewed on the IAPD website.
  • Search Functionality: Users can search for both SEC-registered and state-registered investment advisers, and when applicable, the search results will also include information from FINRA’s BrokerCheck database.
  • Content of Records: The public record includes the registration or reporting form (Form ADV) an adviser has submitted, detailing the firm's operations, investment strategies, and risk acknowledgement.

The IAPD platform serves as a tool for due diligence, allowing investors to make informed decisions by reviewing the information that investment advisors are required to disclose.

Understanding Fee Structures

When investors engage with financial advisors, the fee structures outlined in Form ADV become a pivotal aspect of the contractual relationship. These structures dictate how advisors are compensated and can significantly impact the overall costs of portfolio management services.

Advisory Fees and Costs

Fixed Fees: Advisors may charge a fixed fee for their services, which is detailed in the Form ADV. This fee does not vary with the size or performance of the portfolio. Performance-Based Fees: Some advisors can also charge fees based on the performance of the investments they manage. They outline the specifics of this arrangement in their Form ADV. Asset-Based Fees: It is common for advisors to charge a percentage of the assets under management (AUM). This method aligns the advisor's compensation with the account size, incentivizing them to increase the value of their clients' portfolios.

Other Fees and Expenses

Operating Expenses: Investors often incur additional operating costs that are not included in the advisory fee. These may include transaction costs, custodial fees, and other operational expenses. Expense Ratios for Mutual Funds or ETFs: If an investor's portfolio includes mutual funds or ETFs, each fund may have its own set of fees, called expense ratios, which are separate from the advisor's fees.

In summary, Form ADV provides insights into how advisors charge for their services, which is vital for investors to understand the full scope of their financial engagement. These fee structures play a crucial role in the economics of investment advisory relationships and directly affect an investor's net returns.

Legal and Organizational Structure

Investment advisers are required to disclose specific legal and organizational details impacting their operations. This includes affiliations with other entities, the structure of ownership, and the control of the firm, each impacting their regulatory responsibilities and client relationships.

Affiliations and Associations

Investment advisory firms must disclose any affiliations and associations they have with other financial institutions or entities that could represent a conflict of interest or affect their advisory operations. Item 1 of Form ADV necessitates advisers to list:

  • Legal Affiliations: Any financial industry-related companies, such as broker-dealers or banks, with which the adviser is connected.
  • Business Associations: Non-financial entities or services that might influence the adviser's recommendations or services.

It is essential for clients to understand these affiliations, as they can impact the types of products and services offered and potentially lead to conflicts of interest.

Ownership and Control

Form ADV requires advisers to outline their ownership and control structure. Advisers provide this information in Item 1:

  • List of Owners: Investment advisers must identify any person or company that has ownership interest. Ownership must be explicitly detailed if it equates to 25% or more of the organization.
  • Percentage of Ownership Name of Owner Above 25% Specific individuals, companies, or entities identified
  • Control Persons: Those with executive control or influence over the management of the adviser's affairs. This includes officers, directors, and partners who make significant business decisions.
  • Control Person Title/Position Name of Individual CEO, Managing Partner, Director, etc.

Understanding the ownership and control landscape is paramount, as it can affect decision-making and the strategic direction of the firm, ultimately impacting the services provided to clients.

Registration and Filing Procedures

Investment advisers are required to complete a robust registration and reporting process primarily through the Investment Adviser Registration Depository (IARD), utilizing Form ADV as a central document.

IARD and Form ADV

The IARD functions as an electronic filing system for investment advisers, facilitating the streamlined submission and updating of Form ADV. All investment advisers that are registering with the SEC or state securities authorities must employ this system. The Form ADV itself consists of a Uniform Application for Investment Adviser Registration and a Report by Exempt Reporting Adviser. It's designed in a check-the-box, as well as fill-in-the-blank format, to simplify the disclosure of pertinent information.

Key functions within the IARD for Form ADV include:

  • Initial Registration: Advisers must electronically file Form ADV to apply for registration with the SEC and/or state regulators.
  • Annual Amendment: An annual update is mandatory, where advisers revise their Form ADV to reflect current and accurate information for each fiscal year.
  • Other-Than-Annual Amendment: Should any material changes occur, investment advisers are required to amend their Form ADV promptly.

Submissions through the IARD are subject to certain filing and other fees, which varies depending on the adviser’s regulatory assets under management (AUM) and the states in which they operate.

Form ADV-H

In exceptional circumstances, if an investment adviser encounters hardships that limit their ability to access the electronic IARD system, they can use Form ADV-H. This form allows them to request a temporary or continuing hardship exemption for their filing requirements. The scenarios where this may apply include:

  • Temporary Hardship: A short-term inability to access the IARD system, requiring expedited processing of a paper filing.
  • Continuing Hardship: Ongoing issues that prevent electronic filing, necessitating a longer-term exemption.

It is integral for investment advisers to comply with the specific procedures for Form ADV-H to ensure they maintain adherence to filing requirements amidst technological or other operational difficulties.

Operational Aspects

In addressing the operational aspects of Form ADV, investment advisers disclose detailed information concerning their brokerage practices and client referral arrangements. This mandatory transparency ensures that all parties understand the adviser's operations and potential conflicts of interest.

Broker-Dealer Relationships and Brokerage Practices

An investment adviser details its relationships with broker-dealers and its brokerage practices to illuminate how it selects or recommends broker-dealers for client transactions. The Form ADV requires that advisers specify:

  • Direct Relationships: Firms must disclose any direct or indirect relationships with broker-dealers and how these relationships could influence their recommendations to clients.
  • Client Brokerage: The document outlines the adviser’s approach to selecting or recommending broker-dealers, including considerations such as the cost, efficiency, and promptness of transactions.

Client Referral Arrangements

Transparency regarding client referral arrangements is critical for investors to understand the incentives behind recommendations made by investment advisers. Advisers must disclose:

  • Existence of Arrangements: Any arrangements where the adviser receives client referrals from third parties.
  • Compensation Structures: Details regarding compensation to and from referral sources. This often includes both cash and non-cash compensation, highlighting any potential conflicts of interest that may arise from these arrangements.

Strategy and Management

Investment advisers delineate their strategy and management practices through documents such as Form ADV, which serves as a disclosure document for clients. It typically outlines how firms manage assets and the approaches they employ concerning portfolio management.

Portfolio Management Approaches

Investment strategies outlined in Form ADV describe how advisers allocate and manage clients' assets. Firms may adopt various investment philosophies, from value investment strategies, which focus on undervalued securities, to active international allocation strategies that seek opportunities in global markets. The document should reveal the assets under management and how these assets are strategically allocated, often providing an insight into which sectors or financial instruments they prefer.

Assets Managed: Firms report the scale of their management, such as the aggregate assets under management, which gives an indication of the firm’s size and capacity.

Side-by-Side Management

Side-by-Side Management: This involves an investment adviser managing both private funds and mutual funds or other types of accounts in parallel. It is crucial to disclose how advisers mitigate potential conflicts of interest. Clients are often interested in how a firm ensures fair and equitable allocation of investment opportunities when managing side-by-side funds.

Firms must demonstrate their commitment to treating all managed accounts equally and providing transparent strategies that detail their approach to side-by-side management.

Business Continuity and Disaster Recovery

In the realm of finance, a robust Business Continuity and Disaster Recovery (BCDR) strategy is imperative for businesses to maintain operational integrity in the face of disruptions.

Preparation and Planning

Business Continuity (BC) refers to the processes and procedures a business implements to ensure that essential functions can continue during and after a disaster. BC planning involves identifying critical operations and creating logistical plans for how these can be maintained or quickly resumed in a crisis.

  • Risk Assessment: Cataloging potential threats and determining how they might impact business operations.
  • Business Impact Analysis (BIA): Quantify the effect of disruptions on various business functions.
  • Strategy Development: Establishing procedures to support business operations during different types of emergencies.

Disaster Recovery (DR) focuses on the restoration of IT systems, data, and infrastructure after a disaster. It is a critical subset of overall business continuity.

  • Data Backup: Regularly scheduled backups to secure locations.
  • Recovery Sites: Implementing alternate work sites or data centers.
  • Testing and Drills: Regular exercises to ensure that recovery procedures are effective and up-to-date.

Together, these practices ensure that a business can withstand and swiftly recover from disruptive events, safeguarding both operational capacity and stakeholder trust.

Glossary

In the context of Form ADV and investment adviser registration, certain terms hold specific legal and regulatory significance. The glossary section aims to define key terms that are essential for understanding the registration process and the entities involved.

Key Terms Defined

  • Exempt Reporting Adviser (ERA): An investment adviser that is not required to register with the SEC, but must report certain items because they advise venture capital funds or private funds under a certain size. They must complete a limited portion of Form ADV for these reports.
  • Financial Industry Regulatory Authority (FINRA): A private, self-regulatory organization authorized by Congress to protect investors by ensuring the securities industry operates fairly and honestly. It is not directly involved with the Form ADV, but oversees brokerage firms and their agents.
  • North American Securities Administrators Association (NASAA): An organization of securities regulators whose goal is to protect consumers who purchase securities or investment advice. NASAA provides resources to enhance the quality of Form ADV through education and coordination with the SEC.
  • Plain English Summary: A part of the Form ADV where investment advisers provide a narrative brochure written in plain English that describes their services, fees, strategies, risks, and disciplinary information, to make it understandable to investors.
  • U.S. Securities and Exchange Commission (SEC): The federal agency responsible for enforcing the federal securities laws and regulating the securities industry, the nation's stock and options exchanges, and other electronic securities markets in the United States. Investment advisers register with the SEC using Form ADV, which requires comprehensive disclosure about the adviser's business.

Adviser Resources

Investment advisers have a wealth of resources at their disposal to ensure compliance with Form ADV requirements and to maintain a high standard of professional knowledge and competency.

Professional Organizations and Support

Securities and Exchange Commission (SEC) and State Regulators: Advisers must register with the SEC or state securities authorities using Form ADV, which provides a detailed overview of their business, ownership, clients, employees, business practices, affiliations, and any disciplinary events of the adviser or its employees.

  • Investment Adviser Association (IAA): This organization offers compliance assistance, educational seminars, and legal advocacy to support investment advisers in understanding regulatory requirements, including those related to Form ADV.
  • Financial Industry Regulatory Authority (FINRA): While FINRA is primarily known for its regulation of broker-dealers, its BrokerCheck system is a useful tool for investment advisers to check their own records and those of other entities for transparency and due diligence purposes.

Educational Resources

Continuing Education: Investment advisers are encouraged to engage in continuing education programs to stay abreast of changes to Form ADV and other regulatory updates.

  • Online Courses and Webinars: Many professional organizations and educational institutions offer courses covering compliance with the Investment Advisers Act of 1940 and Form ADV filing requirements.
  • Research and Publications: Advisers should access the latest research and publications related to investment advisory practices to enhance their understanding and provide better services to their clients.

Frequently Asked Questions

The following subsections address some of the most common inquiries regarding SEC Form ADV to assist investment advisors and interested parties.

What is the purpose of SEC Form ADV in the investment advisory process?

SEC Form ADV serves as the primary disclosure document that investment advisors use to register with both the Securities and Exchange Commission (SEC) and state securities authorities. It provides detailed information about an advisor’s business, ownership, clients, employees, business practices, affiliations, and any disciplinary events of the advisor or its employees.

How can one obtain a sample of Form ADV for reference?

A sample of Form ADV can be obtained directly from the SEC's website or through the Investment Adviser Registration Depository (IARD) system. The IARD platform is the electronic system used to submit Form ADV and its amendments to the SEC.

What essential information is included in Part 1A of Form ADV?

Part 1A of Form ADV requires information about the investment advisor's business, ownership structure, clients, employees, and regulatory business history. This part also inquires about the advisor's affiliations and any potential conflicts of interest that could affect their advisory services.

Can you explain what Form ADV Part 2B covers regarding advisor information?

Form ADV Part 2B, often referred to as the "brochure supplement," provides information about the specific individuals acting on behalf of an investment advisor who actually provides investment advice and interacts with clients. It includes details on the educational background and business experience of these advisors.

What are considered material changes requiring an update to Form ADV?

Material changes that require an update to Form ADV include significant alterations in the investment advisor’s business operations, changes in fee structures, disciplinary information, or a change in contact information. Any amendments to advisory services or policies that are relevant to a client's or the public's evaluation of the advisor or its associated risks also necessitate an update.

How frequently are investment advisors required to update their Form ADV?

Investment advisors must update their Form ADV at least annually, within 90 days of the end of their fiscal year. They must also amend their Form ADV promptly whenever certain information becomes inaccurate in any way, such as material changes to their business practices, disciplinary information, or other critical updates.