IARD System Frequently Asked Questions - Form Filing for IA Firms
ADV Part II
1. Do firm users need entitlement to file Part II of Form ADV in IARD?
In order to file Part II of Form ADV, the user must have entitlement to submit Forms ADV and ADV-W. There is no new ADV Part II entitlement for firm users.
2. Is my firm required to file Part II of Form ADV through IARD?
For policy questions related to Form ADV, firms should contact the regulator(s) directly. A list of jurisdiction regulators can be found on http://www.nasaa.org.
Note to SEC-registered advisers: The SEC does not require SEC-registered advisers to file Part II of Form ADV electronically. Regardless of whether your firm files its Part II through IARD, your firm must continue to provide prospective clients with a copy of Part II or a brochure containing at least the same required information. A copy of Part II also must be kept in your office for inspection by the SEC. See Rules 203-1(b)(2), 204-1(c) and 204-3 of the Investment Advisers Act for details of your legal obligations concerning Part II of Form ADV.
3. What information should I include in my brochure?
For questions related to the contents of brochures, firms should contact the regulator(s) directly. A list of jurisdiction regulators can be found on http://www.nasaa.org.
4. Is ADV Part II a separate form in IARD?
No, Part II is simply the second part of Form ADV (i.e. Part 1) and can be accessed by opening a Form ADV filing.
5. How do I know if my brochure is text-searchable?
To test if your brochure is text-searchable:
- Open the PDF file
- Click Edit from the Tool Bar
- Click Find from the menu options
- Search for a word in the document
If you are able to perform a word search, the document is text-searchable.
6. Can I amend the Brochure Name, Brochure Description and Types of Business on a brochure filing without attaching a new version of the brochure?
No. A new brochure attachment is required if the brochure metadata (i.e. Brochure Name, Description, and Brochure Type) is changed.
7. I've created a new brochure on a Part II filing by entering the Brochure Name, Brochure Description and Type of Business but I do not see a button to upload the brochure. Where should I click to upload my document?
You will be prompted to upload the new brochure after clicking the Submit Filing hyperlink in the navigation panel.
8. If you retire a brochure can you change the brochure description?
No. Firms cannot amend a brochure after it has been retired. If the firm wants to retire a brochure but they have changes, they must amend the brochure first then retire it.
9. Will retired brochures display on IAPD?
Retired brochures will not display in IAPD. However, retired brochures will display in IARD.
10. I am trying to perform a Brochure Search by entering Brochure Name in the search criteria. However, the results do not contain the brochure I am searching for. Why?
The Brochure Search functionality only searches for content within a brochure. The Brochure Name and Brochure Description are not included as search criteria. Your search criteria should consist of a word or phrase found within the brochure content.
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