Vertical guide · Updated June 2026

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

Q: How do SEC Form ADV annual update advisory calls generate billing gaps on the March 31 deadline calendar?

SEC-registered investment advisers must file their annual Form ADV amendment within 90 days of fiscal year end under Investment Advisers Act Rule 204-1(a), 17 C.F.R. § 275.204-1(a), creating a March 31 annual amendment deadline for calendar-year advisers. Because most smaller registered investment advisers — wealth management firms, financial planners, family office advisers — use December 31 fiscal year ends, the annual update deadline concentrates advisory calls from all calendar-year adviser clients in the same 6-week February–March window. Three call types: pre-deadline Form ADV compliance review advisory (reviewing Part 1A regulatory AUM, Part 2A material changes, and Part 2B supervised person updates), draft Form ADV review advisory (reviewing updated sections for accuracy and conflict-of-interest disclosure completeness under IAA § 206, 15 U.S.C. § 80b-6), and post-filing brochure delivery advisory (confirming Part 2A brochure delivery to existing advisory clients within 30 days under Rule 204-3(b)(2)). At 55% untracked: 9 clients × 3 calls × 25 min × 55% ≈ 6.2 hours = $2,790–$4,650/year at $450–$750/hr.

Q: How do SEC EXAM examination preparation advisory calls generate billing gaps on EXAM's scheduling calendar?

The SEC Office of Examinations (formerly OCIE) conducts risk-based examinations of registered investment advisers, including cause examinations triggered by investor complaints and routine examinations prioritized by the EXAM risk-ranking model. EXAM initiates examinations on its own scheduling calendar — not coordinated with the investment adviser compliance attorney's billing schedule — sending an Initial Information Request (IIR) letter with a 2-week production deadline as the examination's first formal event. Advisory calls arrive across four stages: IIR receipt and production advisory (reviewing the IIR's document request scope and advising on the production strategy, privilege assertions, and the 2-week production deadline under the EXAM examination process); on-site examination advisory (advising on staff interviews, books-and-records inspection logistics, and the adviser's real-time response obligations during the on-site visit); preliminary deficiency discussion advisory (advising on EXAM staff's preliminary findings before the deficiency letter is issued, including the rebuttal strategy and whether to seek a corrective action plan); and deficiency letter response advisory (advising on the scope and adequacy of proposed corrective actions and the deadline for written response). At 55% untracked: 3 clients × 4 calls × 44 min × 55% ≈ 4.8 hours = $2,160–$3,240/year at $450–$675/hr.

Investment adviser compliance attorneys advising SEC-registered investment advisers on Form ADV annual updates under Investment Advisers Act Rule 204-1(a), 17 C.F.R. § 275.204-1(a) and the March 31 annual amendment deadline, preparing registered investment advisers for SEC Office of Examinations (EXAM) examinations on EXAM's scheduling calendar, and conducting Investment Advisers Act Rule 206(4)-7, 17 C.F.R. § 275.206(4)-7, compliance program annual reviews on the adviser's fiscal year-end calendar — whose time records must satisfy the investment adviser compliance documentation standard and the EXAM records inspection requirement — generate three billing gaps driven by the concentrated March 31 annual amendment deadline, the unpredictable EXAM examination initiation calendar, and the year-end compliance program review cycle: Form ADV annual update advisory calls on the March 31 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 scheduling calendar (3 clients × 4 calls × 44 min × 55% ≈ 4.8 hrs = $2,160–$3,240/year at $450–$675/hr), and IAA Rule 206(4)-7 compliance program annual review advisory calls on the adviser's fiscal year-end calendar (6 clients × 2 calls × 31 min × 55% ≈ 3.4 hrs = $1,530–$2,295/year at $450–$675/hr). For an investment adviser compliance solo practice, the annual billing gap is $6,480–$10,185.

TL;DR

ClaimHour captures every Form ADV pre-deadline compliance review advisory call that arrives in the compressed February–March window before the March 31 annual amendment deadline, every SEC EXAM initial information request advisory call that arrives on EXAM's unannounced examination initiation calendar, and every Rule 206(4)-7 compliance program annual review advisory call that arrives in the concentrated October–December year-end review 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 deadline calendar

SEC-registered investment advisers — including wealth management firms, financial planners, portfolio managers, and family office advisers — must file their annual Form ADV amendment within 90 days of fiscal year end under Investment Advisers Act Rule 204-1(a), 17 C.F.R. § 275.204-1(a). For investment advisers using a December 31 fiscal year end — which is the default for most smaller registered investment advisers who have not elected a non-calendar fiscal year — the annual amendment deadline falls on March 31 of each year. The March 31 annual amendment deadline creates a concentrated advisory call burden because all calendar-year adviser clients face the same annual amendment deadline simultaneously: an investment adviser compliance attorney with 9 calendar-year adviser clients will receive annual update advisory calls from all 9 clients in the same 6-week February–March window, rather than spread across 12 months on a client-by-client schedule. The Form ADV annual update advisory call burden covers four Form ADV components requiring annual review: (1) Form ADV Part 1A (regulatory assets under management, number of advisory clients, types of advisory clients, disciplinary information, and financial industry affiliations — each of which requires recalculation or verification as of December 31); (2) Form ADV Part 2A brochure (written narrative description of the adviser's investment strategies, fee schedules, types of clients served, methods of analysis, and conflicts of interest — requires supplementation for any material changes during the year under Rule 204-3(b)(1)); (3) Form ADV Part 2B brochure supplement (descriptions of supervised persons who formulate investment advice — requires updates for changes in disciplinary history, educational background, and outside business activities); and (4) Form CRS relationship summary for registered investment advisers that are also registered as broker-dealers or that have broker-dealer affiliates.

Three Form ADV annual update advisory call types that arrive on the March 31 deadline calendar: (1) pre-deadline Form ADV compliance review advisory call — arrives 2–4 weeks before March 31, when counsel must review the adviser's Form ADV Part 1A for regulatory AUM accuracy (including the methodology for calculating discretionary versus non-discretionary AUM under Form ADV Glossary), Part 2A for material changes requiring supplemental delivery to existing clients under Rule 204-3(b)(1), and Part 2B for changes to supervised persons' disciplinary history under Item 3 of the brochure supplement (23–28 min) — on the annual amendment pre-deadline calendar, concentrating in February for calendar-year advisers; (2) Form ADV draft review advisory call — arrives 1–2 weeks before March 31, when counsel reviews the draft updated Form ADV for accuracy, completeness of conflict-of-interest disclosure under Rule 206(4)-7's requirement that the code of ethics and conflict-of-interest policies be reflected in the Part 2A brochure's Item 11, and sufficiency of the risk disclosure for complex investment strategies under SEC staff guidance in the Form ADV Part 2 adopting release (Release IA-3060) (23–28 min); (3) post-filing brochure delivery advisory call — arrives after the March 31 annual amendment filing, when counsel must confirm that Part 2A brochures with material changes were delivered to existing advisory clients within 30 days of the annual amendment under Rule 204-3(b)(2), advise on the method of brochure delivery acceptable for the adviser's client base (email, website posting, or paper), and confirm that Part 2B brochure supplements were provided to advisory clients whose supervised persons changed (23–28 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 scheduling calendar

The SEC Office of Examinations conducts examinations of registered investment advisers under the Investment Advisers Act of 1940 and the Investment Company Act of 1940, using a risk-based examination selection model that prioritizes advisers for examination based on regulatory AUM, years since last examination, complexity of investment strategies, investor complaints, and referrals from the SEC's Division of Enforcement. EXAM initiates examinations on its own scheduling calendar — not at a time coordinated with the investment adviser compliance attorney's billing schedule — by sending an Initial Information Request (IIR) letter to the registered investment adviser, which sets a 2-week deadline for document production and notice that EXAM staff will arrive for an on-site examination. Because EXAM's examination risk-selection model operates confidentially, investment adviser compliance attorneys cannot schedule or anticipate when an EXAM examination will be initiated for any of their advisory clients: the IIR letter arrives without prior notice, requiring the attorney to immediately mobilize a document production response, advise on privilege assertions, and prepare the adviser's principals for EXAM staff interviews — all on EXAM's examination calendar, not the attorney's billing schedule. Advisory calls arrive across four examination stages: the IIR receipt and production advisory stage (when EXAM issues the IIR letter and requires document production within 2 weeks), the on-site examination advisory stage (when EXAM staff arrives at the adviser's office for books-and-records inspection and principal interviews), the preliminary deficiency discussion stage (when EXAM staff shares preliminary findings before the formal deficiency letter), and the deficiency letter response stage (when EXAM issues the formal deficiency letter requiring a written response).

Four SEC EXAM examination preparation advisory call types that arrive on EXAM's scheduling calendar: (1) EXAM Initial Information Request receipt and production advisory call — arrives when EXAM issues the IIR letter with a 2-week document production deadline, when counsel must advise on the scope of the IIR's document requests, assert attorney-client privilege and work product protection for relevant documents, negotiate the production timeline with EXAM staff, and advise on the adviser's document preservation obligations during the examination (42–52 min) — on EXAM's examination initiation calendar, arriving without advance notice; (2) EXAM on-site examination advisory call — arrives when EXAM staff schedules the on-site examination date, when counsel must prepare the adviser's chief compliance officer and principals for EXAM staff interviews, advise on the books-and-records inspection process under Rule 204-2 (Books and Records Rule), and advise on the real-time response protocol for EXAM staff requests for additional documents during the on-site visit (42–52 min); (3) EXAM preliminary deficiency discussion advisory call — arrives when EXAM staff shares preliminary findings at the conclusion of the on-site examination, when counsel must advise on the significance of the preliminary findings in the context of recent EXAM enforcement referrals, the availability of a rebuttal submission before the formal deficiency letter, and the corrective action plan options that may avoid the most serious deficiency categories (40–50 min); (4) EXAM deficiency letter response advisory call — arrives when EXAM issues the formal deficiency letter requiring a written response within 30 days, when counsel must advise on the scope and adequacy of the proposed corrective actions, the sufficiency of the corrective action timeline in the context of EXAM's follow-up examination schedule, and the risk that unresolved deficiencies will be referred to the SEC's Division of Enforcement (40–50 min). At 55% untracked: 3 clients × 4 calls × 44 min × 55% = 290.4 min / 60 ≈ 4.8 hours = $2,160–$3,240/year at $450–$675/hr.

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

Investment Advisers Act Rule 206(4)-7, 17 C.F.R. § 275.206(4)-7, requires every SEC-registered investment adviser to adopt and implement written policies and procedures reasonably designed to prevent violations of the Investment Advisers Act and the rules thereunder, and to review those policies and procedures at least annually to assess their adequacy and the effectiveness of their implementation. The Rule 206(4)-7 annual review obligation creates a year-end advisory call cycle because most registered investment advisers conduct their annual review in conjunction with their fiscal year-end compliance calendar: the chief compliance officer prepares an annual review report for presentation to senior management (typically in November or December), and the investment adviser compliance attorney must advise on the scope and content of the annual review, the adequacy of the policies and procedures updates, and the documentation standard that will satisfy EXAM staff inspection of the annual review materials. The annual review advisory call burden arises from the breadth of Rule 206(4)-7's requirements: the written policies and procedures must address all significant compliance risks facing the adviser, including compliance risks identified by EXAM staff in recent examination deficiency letters, compliance risks identified in annual EXAM risk alerts, and compliance risks arising from changes in the adviser's business, strategies, or personnel during the year. For investment adviser compliance attorneys advising multiple registered investment advisers, all of whom conduct their Rule 206(4)-7 annual reviews in the October–December window, the annual review advisory call burden clusters at year-end — creating a concentrated billing gap in the same months as the attorney's other year-end compliance obligations.

Two IAA Rule 206(4)-7 compliance program annual review advisory call types that arrive on the fiscal year-end calendar: (1) Rule 206(4)-7 annual review scope and documentation advisory call — arrives in October–November when the adviser's chief compliance officer begins the annual review process, when counsel must advise on the scope of the annual review (identifying new EXAM risk alerts, SEC no-action letters, and enforcement actions from the prior year that require policy updates), the documentation of the annual review in a written report under SEC guidance in the Compliance Program adopting release (Release IA-2204), and the content of the CCO's annual review presentation to senior management, which should document both the review process and the resulting changes to written policies and procedures (28–35 min) — on the fiscal year-end annual review calendar; (2) Rule 206(4)-7 compliance manual update and CCO certification advisory call — arrives in November–December when the adviser completes the annual review and must update its compliance manual to reflect identified policy gaps, amend its code of ethics to reflect changes in supervised persons' personal trading obligations under Rule 204A-1, update its insider trading policy to reflect changes in the adviser's access to material non-public information, and document the CCO's certification that the annual review was completed in accordance with the Rule 206(4)-7 requirements (28–35 min). At 55% untracked: 6 clients × 2 calls × 31 min × 55% = 204.6 min / 60 ≈ 3.4 hours = $1,530–$2,295/year at $450–$675/hr.

How ClaimHour fits investment adviser compliance practice

If you advise registered investment advisers on Form ADV annual updates with pre-deadline compliance review calls and draft Form ADV review calls arriving in the concentrated February–March window before the March 31 annual amendment deadline, prepare registered investment advisers for SEC EXAM examinations with initial information request advisory calls and preliminary deficiency discussion advisory calls arriving on EXAM's unannounced scheduling calendar, and conduct IAA Rule 206(4)-7 compliance program annual reviews with annual review scope and compliance manual update advisory calls arriving in the concentrated October–December year-end review window — and your invoices consistently understate the post-filing brochure delivery advisory calls that arrive after March 31, the EXAM on-site examination advisory calls that arrive on EXAM's examination scheduling calendar, and the Rule 206(4)-7 CCO certification advisory calls that arrive in the final weeks of the fiscal year — ClaimHour was built for that gap.

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