Reminder to RIAs - May 1st is the deadline for "Delivery" of your new ADV Part 2A.
For RIAs with a fiscal year end of December 31st, the filing deadline for your new plain English ADV2 was March 31st, 2011. The next step is to deliver the ADV2 (your "Disclosure Brochure") to your existing clients. The delivery deadline is May 1, 2011, which is fast approaching!
What is meant by "Delivery"?
Delivery of your Disclosure Brochure can be accomplished in several ways, but it must be a push of the actual Disclosure Brochure in a manner that that client will receive the document. In contrast to an offer where you inform the client as to how they might obtain the Disclosure Brochure.
- Email - if you currently communication with your clients via email, you can email as an attachment (in in-line in the message if you can make it work). For the attachment, be sure to use a universal format, like a PDF file. YOU CANNOT sent a link to the client bringing them back to your website or the Investment adviser public disclosure website. That is just an "offer". Your email saved in your archives will serve as your proof of delivery.
- Mail - of course you can always mail your document, but at an average of 15+ pages for the ADV 2A and 3 pages for each ADV2B, that is a less than appealing option for Advisors. And the clients probably don't want the paper! Of course you may have some clients that don't user email, so this is you only option. You will want to maintain proof of delivery, such as the postal receipt and a list of mail recipients with the date mailed.
- Hand Delivery - you can certainly hand deliver the Disclosure Brochure. Be sure to track the activity in your CRM system. If you don't have a CRM, you may want to consider an ADV Delivery log that you keep with the date and time of delivery to each client.