Practice management
The filing arrives as a scramble in March. The annual review happens in December, or it does not. None of this work is hard — it is simply unmapped.
Most firms handle compliance as a series of surprises. The ADV amendment arrives as a scramble in March. The annual review happens in December, or does not. Somebody remembers the code of ethics acknowledgments in the week they are due.
None of this work is hard. It is simply unmapped, so it always arrives at once and always feels urgent.
Your obligations depend on your registration and your business, and your chief compliance officer owns the list. But the shape of the year is broadly the same for most advisory firms:
| When | What | Why it slips |
|---|---|---|
| Q1 | Annual updating amendment to Form ADV, within 90 days of fiscal year end. Delivery of the brochure or a summary of material changes. | The data comes from four places and one of them is a spreadsheet |
| Q1 | Confirm assets under management, client counts and fee schedules match what you are about to file. | Nobody reconciles the filing against the billing system |
| Ongoing | Personal trading reports and code of ethics acknowledgments on whatever cadence your manual states. | The manual says quarterly and the firm does it annually |
| Ongoing | Advertising review and substantiation for anything published. | Marketing ships faster than compliance reviews |
| Annual | The compliance program review, documented. | It happens and nobody writes it down, which is the same as not happening |
| Annual | Business continuity and vendor oversight review. | Treated as paperwork rather than as a real question |
Two or three dates each year cannot move. Everything else can. Put the immovable ones in first, then place the work that feeds them four to six weeks earlier, so the filing is an output rather than a project.
The reconciliation that supports your ADV figures should happen in January, not the week the form is due. That single change removes most of the March scramble.
Assign every recurring item an owner and a date, in one place your whole firm can see. Not the compliance manual — a calendar. The manual describes the policy; the calendar is what makes it happen.
And document as you go. A short note recording what was reviewed, when, by whom, and what was found takes ten minutes at the time and is impossible to reconstruct a year later.
Not on the big filings. Those have deadlines and deadlines get met. They get caught on the annual review that was never written up, the advertising figure nobody can trace, and the fee schedule that was amended by email in 2023.
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