Guide to SEC Form ADV, Form PF, and RIA Compliance Calendars
Investment advisers operating in the United States face strict statutory filing obligations. Managing the compliance calendar requires absolute precision, as filings are routed through different portals (such as the IARD system and the SEC's EDGAR portal) and carry distinct, mandatory deadlines governed by the Investment Advisers Act of 1940 and related SEC rules.
The Annual Form ADV Amendment (SEC Rule 204-1)
Under Advisers Act Rule 204-1, every registered investment adviser (RIA) must file an annual amendment to Form ADV within 90 days after the end of its fiscal year. This filing is completed electronically on the Investment Adviser Registration Depository (IARD) portal. For advisers with a standard calendar fiscal year-end (December 31), this deadline is typically March 31. However, because this is a calendar day computation, the deadline occasionally falls on a weekend, activating holiday-shifting rules.
Exempt Reporting Advisers (ERAs), which rely on the private fund adviser exemption (under Section 203(m)) or the venture capital adviser exemption (under Section 203(l)), are also subject to this annual updating amendment rule. While ERAs complete a subset of Form ADV Part 1, they must adhere to the exact same 90-day filing timeline.
Form ADV Part 2A (Brochure) and Client Delivery (SEC Rule 204-3)
While the Form ADV Annual Amendment updates the regulator, Rule 204-3 requires RIAs to deliver their updated Brochure (Form ADV Part 2A) or a summary of material changes to existing clients within 120 days of the fiscal year-end. For calendar year-end firms, this is April 30. Unlike Form ADV, client delivery is not registered through the IARD portal but must be distributed directly to client accounts via electronic delivery, mail, or secure client portals, and documented thoroughly for regulatory inspections.
Form PF Private Fund Risk Reporting (Rule 204(b)-1)
Advisers that manage one or more private funds (such as hedge funds, private equity funds, or venture capital funds) and have at least $150 million in private fund assets under management are required to submit Form PF. Form PF provides the FSOC with crucial risk-exposure indicators.
Filing deadlines are highly dependent on the private fund asset classes and the adviser's regulatory classification:
- Large Hedge Fund Advisers: Advisers managing at least $1.5 Billion in hedge fund assets. Filing is due quarterly within 60 calendar days of each quarter-end on the PFRD portal.
- Large Liquidity Fund Advisers: Advisers managing at least $1.0 Billion in liquidity funds/money market equivalents. Filing is due quarterly within 15 calendar days of each quarter-end.
- Large Private Equity Advisers: Advisers managing at least $2.0 Billion in private equity fund assets. Filing is due annually within 120 calendar days of the fiscal year-end.
- Smaller Private Fund Advisers: All other advisers managing at least $150 Million in private fund assets. Filing is due annually within 120 calendar days of the fiscal year-end.
Section 13(f) and Section 13(H) (Large Trader) Obligations
Institutional investment managers that exercise investment discretion over accounts holding $100 Million or more in US exchange-listed equity securities (13(f) securities) must file Form 13F. This is a quarterly public holdings disclosure filed via the SEC's EDGAR system within 45 days of each calendar quarter end.
In addition, high-velocity trading managers crossing the "Large Trader" threshold under SEC Rule 13h-1 must file an initial Form 13H within 10 days of crossing the volume threshold (2 million shares / $20 million value in a day, or 20 million shares / $200 million value in a month). Form 13H requires subsequent annual amendments within 45 days of the calendar year-end (February 14).
Holiday and Weekend Shifting Protocols
Because regulatory filing timelines are statutory, they are subject to standard federal and SEC holidays. Under SEC Rule 0-3, if a statutory deadline lands on a Saturday, Sunday, or official SEC Federal holiday, the filing deadline is extended to the next business day. This calculator models these shifting protocols dynamically, mapping federal holidays such as DC Emancipation Day observations, Juneteenth, Veterans Day, and MLK Day to provide professionals with the exact date for safe and compliant submissions.