No, not the NCAA tournament, but rather, the rush to get your annual updating amendment filed by the deadline. Remember that because this year is a Leap Year, the deadline for filing is March 30th and not the usual 31st. SEC firms should also note that they cannot file their annual updating amendment until their IARD user fees have been paid.
The fee schedule is as follows:
|Assets Under Management||Initial Set-Up Fee||Annual Fee|
Under $25 Million
$25 Million – $100 Million
Over $100 Million
|SEC Exempt Reporting Adviser||$150||$150|
Before you go ahead and file your ADV Part 1 and 2A, you should make sure that the information you recorded in one does not conflict with the information in the other. When the assistant director of the SEC’s Office of Compliance, Inspections and Examinations (OCIE) recently listed the top 6 SEC examination deficiencies, accuracy of disclosures and inconsistency between disclosure documents were at the top of the list. These kind of mistakes are easily remedied and quite frankly, there is no excuse for making them other than abject laziness. But do yourself a great favor by eliminating these silly mistakes and avoid the increased scrutiny that comes along with making them.