Fee petition mechanics · Updated June 2026

Investment adviser compliance attorney fee petition mechanics: Form ADV annual update advisory, SEC EXAM examination preparation advisory, and IAA Rule 206(4)-7 compliance program annual review advisory

Investment adviser compliance attorneys representing registered investment advisers in SEC regulatory compliance matters under the Investment Advisers Act of 1940 — whose time records must satisfy the lodestar arithmetic required in any fee petition or sanctions motion arising from an IAA § 203(e) or § 203(f) administrative proceeding involving the same underlying compliance failures — generate three billing gaps driven by the arrival of Form ADV annual update advisory calls on the March 31 EDGAR IARD filing deadline calendar, SEC EXAM examination preparation advisory calls on EXAM's unannounced scheduling calendar, and IAA Rule 206(4)-7 compliance program annual review advisory calls on the October–December year-end calendar: Form ADV annual update advisory calls on the March 31 EDGAR IARD filing deadline calendar (9 clients × 3 calls × 25 min × 55% untracked ≈ 6.2 hrs = $2,790–$4,650/year at $450–$750/hr), SEC EXAM examination preparation advisory calls on EXAM's unannounced scheduling calendar (4 clients × 4 calls × 44 min × 55% ≈ 4.8 hrs = $2,160–$3,240/year at $450–$750/hr), and IAA Rule 206(4)-7 compliance program annual review advisory calls on the October–December year-end calendar (6 clients × 2 calls × 31 min × 55% ≈ 3.4 hrs = $1,530–$2,295/year at $450–$750/hr). For a solo investment adviser compliance practice, the annual billing gap is $6,480–$10,185.

TL;DR

ClaimHour captures every Form ADV annual update advisory call that arrives in the concentrated 6-week February–March IARD deadline window for all 9 IA clients simultaneously, every SEC EXAM examination preparation advisory call that arrives on EXAM's unannounced scheduling calendar without advance notice to counsel, and every IAA Rule 206(4)-7 compliance program annual review advisory call that clusters across all calendar-year IA clients in the October–December window — passively, no timer, no audio, no call contents. $29–$59/mo. No PMS required.

Form ADV annual update advisory: calls on the March 31 EDGAR IARD filing deadline calendar

The Investment Advisers Act of 1940 and SEC rules promulgated thereunder require each registered investment adviser to file an annual amendment to Form ADV with the SEC through the Investment Adviser Registration Depository within 90 days of the adviser's fiscal year end — and for calendar-year advisers, on or before March 31 of each year — under IAA Rule 204-1(a), 17 C.F.R. § 275.204-1(a). The annual Form ADV amendment encompasses three distinct regulatory filings managed through a single IARD submission: Form ADV Part 1 (the structured data filing disclosing the adviser's ownership, business activities, disciplinary history, and regulatory assets under management), Form ADV Part 2A (the narrative brochure disclosing material changes to the adviser's advisory business, fee schedules, conflicts of interest, and disciplinary history required to be delivered to clients under IAA Rule 204-3), and Form ADV Part 3 (Form CRS, the relationship summary required of SEC-registered advisers and dual registrants under Regulation Best Interest). Because all 9 IA clients operating on a calendar-year fiscal year face the same March 31 IARD deadline, advisory calls triggered by the annual Form ADV update obligation concentrate in the same 6-week February–March window each year — a temporal clustering pattern publicly traceable through SEC EDGAR IARD filing history, which discloses each adviser's annual amendment submission date and effective date for all SEC-registered advisers.

Three Form ADV annual update advisory call types that arrive on the March 31 EDGAR IARD filing deadline calendar: (1) Form ADV Part 1 completion and Part 2A narrative update advisory call — arrives 3–4 weeks before the March 31 IARD deadline, requiring analysis of whether changes to the adviser's business during the prior year require disclosure in Form ADV Part 1 (including changes to regulatory assets under management, disciplinary events, ownership changes, affiliated adviser relationships, and business continuity plan updates), whether the Form ADV Part 2A brochure requires material changes disclosures under Rule 204-3(b)(1) triggering a delivery obligation to existing clients within 120 days of fiscal year end, and whether the Part 2A disclosure of conflicts of interest (advisory fee arrangements, soft dollar practices, directed brokerage, affiliated transaction practices, and proprietary trading) remains accurate under Item 10 of Form ADV Part 2A (22–28 min); (2) Form ADV Part 2B supervised person update and form delivery advisory call — arrives within the same IARD deadline window, requiring analysis of whether changes to the adviser's supervised persons' qualifications, disciplinary history, or outside business activities require updates to each supervised person's Form ADV Part 2B brochure supplement, whether the Part 2B update triggers a delivery obligation to clients who receive services from the supervised person under IAA Rule 204-3(b)(2), and whether any disciplinary event disclosed on a supervised person's Part 2B creates a material conflict requiring disclosure in the adviser's Part 2A brochure (22–28 min); (3) Form ADV Part 3 (Form CRS) relationship summary annual update advisory call — arrives within the same IARD window for dual-registrant or SEC-registered IA clients subject to Form CRS requirements, requiring analysis of whether changes to the adviser's services, fees, conflicts, legal and disciplinary history, or key questions satisfy the Form CRS annual review obligation, whether the Form CRS must be filed on IARD and delivered to new retail investors under Regulation Best Interest, and whether the adviser's Form CRS accurately reflects its current service model for retail investors compared to broker-dealers offering similar services (22–28 min). At 55% untracked: 9 clients × 3 calls × 25 min × 55% = 371.25 min / 60 ≈ 6.2 hours = $2,790–$4,650/year at $450–$750/hr.

SEC EXAM examination preparation advisory: calls on EXAM's unannounced scheduling calendar

The SEC Division of Examinations conducts examinations of registered investment advisers under authority granted by IAA § 204, 15 U.S.C. § 80b-4, which authorizes the SEC to examine the books and records of registered advisers at any time. EXAM schedules examinations on a risk-based calendar that takes into account the adviser's prior examination history, the scope of the adviser's regulatory assets under management, the complexity of the adviser's investment strategies, and SEC-wide examination priority areas identified in EXAM's annual examination priorities report. Because EXAM's examination calendar is determined by EXAM's internal risk assessment — not by any external deadline visible to the adviser or counsel — the examination notification letter arrives without advance warning. The adviser typically receives 2–4 weeks' notice before EXAM's on-site examination team arrives (or before the remote examination commences), during which the adviser must assemble responsive documents, prepare personnel for interviews, and assess any compliance deficiencies that EXAM may identify. Advisory calls triggered by EXAM notification therefore arrive on EXAM's calendar, not on any calendar the investment adviser compliance attorney manages, and are systematically underlogged because counsel is responding to EXAM's timeline rather than a predictable internal schedule.

Four SEC EXAM examination preparation advisory call types that arrive on EXAM's unannounced scheduling calendar: (1) initial information request and document production scope advisory call — arrives when EXAM issues the examination notification letter and initial document request, requiring analysis of the scope of documents responsive to EXAM's request (including Form ADV filings, advisory contracts, portfolio management records, trade blotters, compliance policies and procedures, and correspondence with clients), whether any responsive documents are subject to attorney-client privilege or work product doctrine, whether the adviser's document retention practices under IAA Rule 204-2 (the "books and records" rule) have produced any gaps in the required records, and whether to engage outside counsel to manage the document production process (42–48 min); (2) on-site examination preparation and EXAM interview advisory call — arrives when EXAM schedules the on-site (or remote) examination visit, requiring preparation of the adviser's Chief Compliance Officer and portfolio managers for EXAM examiner interviews, analysis of the adviser's compliance testing documentation and annual review under IAA Rule 206(4)-7 to confirm that documented compliance testing exists for all required program areas, review of the adviser's marketing materials for compliance with IAA Rule 206(4)-1 (the "marketing rule"), and preparation of any presentations the adviser intends to make to EXAM staff regarding the adviser's compliance program architecture (42–48 min); (3) preliminary deficiency discussions advisory call — arrives when EXAM staff informally raises concerns before issuing the formal deficiency letter (deficiency letters are typically issued 60–90 days after the on-site examination closes), requiring analysis of whether EXAM's preliminary concerns relate to technical record-keeping deficiencies remediable before the deficiency letter or substantive compliance program failures suggesting referral to the SEC Division of Enforcement, whether the adviser should make voluntary remedial disclosures to EXAM to demonstrate good faith before the deficiency letter is issued, and whether any EXAM concern relates to conduct that might independently trigger a whistleblower complaint under Exchange Act § 21F (40–46 min); (4) deficiency letter response strategy advisory call — arrives when EXAM issues the formal deficiency letter (also called an examination findings letter), typically requiring a written response within 30 days, requiring analysis of each deficiency cited (whether it constitutes a technical record-keeping deficiency or a substantive violation of the IAA or Exchange Act), whether the adviser's remedial actions taken after the examination closes are responsive to each cited deficiency, whether any deficiency cited is incorrect as a matter of law or fact and should be contested in the response letter, and whether the overall pattern of deficiencies cited suggests that EXAM intends to recommend referral to the SEC Division of Enforcement for an IAA § 203(e) proceeding (40–46 min). When EXAM deficiency findings are referred to the SEC Division of Enforcement and the adviser prevails in an IAA § 203(e) administrative proceeding where the Enforcement Division's position was not substantially justified, EAJA 5 U.S.C. § 504 covers the examination advisory call lodestar under Pierce v. Underwood, 487 U.S. 552 (1988). At 55% untracked: 4 clients × 4 calls × 44 min × 55% = 387.2 min / 60 ≈ 4.8 hours = $2,160–$3,240/year at $450–$750/hr.

IAA Rule 206(4)-7 compliance program annual review advisory: calls on the October–December year-end calendar

IAA Rule 206(4)-7, 17 C.F.R. § 275.206(4)-7, requires each registered investment adviser to adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the IAA and SEC rules, to designate a Chief Compliance Officer responsible for administering the compliance program, and to review the compliance program no less frequently than annually to assess its adequacy and the effectiveness of its implementation. The annual review obligation imposes no fixed calendar date — IAA Rule 206(4)-7 requires only that the annual review occur at least once in each calendar year. However, calendar-year advisers whose CCOs align the annual review with the adviser's fiscal year-end reporting cycle typically conduct the annual review in October through December, generating a concentration of advisory calls across all calendar-year IA clients in the same 60–90 day window each year. This October–December clustering pattern — the most predictable single concentration in IA compliance practice — is visible from SEC EDGAR IARD filing history alone, because annual Form ADV amendments filed in February–March of the following year disclose whether the adviser conducted an annual review of its compliance program in the prior year, enabling a billing expert to trace the advisory call pattern backward through the public record.

Two IAA Rule 206(4)-7 compliance program annual review advisory call types that arrive on the October–December year-end calendar: (1) Rule 206(4)-7 compliance program annual review scope and documentation advisory call — arrives when the adviser's CCO initiates the annual review of the compliance program as required by IAA Rule 206(4)-7, requiring analysis of the scope of the annual review (which program areas require compliance testing during the annual review, including portfolio management, trading practices, marketing, proxy voting, privacy, and business continuity), whether the compliance testing methodology produces documented evidence of testing outcomes sufficient to satisfy EXAM's expectation of a comprehensive annual review, whether the adviser's written compliance policies and procedures require updates to reflect changes in the adviser's business activities or SEC regulatory guidance issued during the prior year, and whether the CCO has sufficient authority and resources to conduct an effective annual review under the structural requirements of IAA Rule 206(4)-7 (29–33 min); (2) Rule 206(4)-7 annual review written report board presentation advisory call — arrives when the adviser's CCO finalizes the written annual review report required for presentation to the adviser's board of directors or principal executive (if the adviser is organized as a partnership or LLC without a board), requiring analysis of whether the written annual review report adequately documents the testing methodology, the material compliance risks identified during the annual review, the remedial actions taken or planned in response to identified deficiencies, and the CCO's assessment of the compliance program's adequacy — the written annual review report is typically the first document EXAM requests when conducting an examination of the adviser's compliance program, and its quality directly affects the scope and duration of the EXAM examination (29–33 min). All 6 calendar-year clients concentrate 12 advisory calls in the same October–December window — a 60–90 day temporal clustering pattern visible from SEC EDGAR filing history alone. At 55% untracked: 6 clients × 2 calls × 31 min × 55% = 204.6 min / 60 ≈ 3.4 hours = $1,530–$2,295/year at $450–$750/hr.

How ClaimHour fits investment adviser compliance practice

If you represent registered investment advisers in SEC regulatory compliance matters under the Investment Advisers Act of 1940 with Form ADV annual update advisory calls concentrating across all 9 IA clients in the same 6-week February–March IARD deadline window, SEC EXAM examination preparation advisory calls arriving on EXAM's unannounced scheduling calendar without advance notice, and IAA Rule 206(4)-7 compliance program annual review advisory calls clustering across all calendar-year IA clients in the same October–December window — and your invoices consistently understate the Form ADV Part 2A narrative update advisory calls that arrive in the February–March IARD window simultaneously for all clients, the EXAM preliminary deficiency discussion advisory calls that arrive when EXAM informally raises concerns before the formal deficiency letter, and the Rule 206(4)-7 written annual review report board presentation advisory calls that cluster in October–December — ClaimHour was built for that gap.

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