Agent pulls last year's filing as baseline, queries every source system, drafts a redlined Part 1A and Part 2A, and auto-generates a Part 2B for every qualifying advisor. The CCO reviews a 98 percent complete draft in under a day instead of assembling data for three months.
Form ADV Preparation Takes Three Months of Compliance Work, Most of It Data Assembly
The Problem
Form ADV Part 1A lives in EDGAR, an SEC filing language written in the mid-1980s that the firm has to literally learn to operate. Part 2A is a Word document narrative, the firm brochure, where the first page must enumerate every change since last year. Part 2B is a separate per-supervised-person brochure required for every advisor who qualifies. Part 3 is the CRS that goes out to every retail relationship. All of it is due by the end of March. The form itself has not meaningfully changed in twenty-five years.
The data does not live in one place. The CCO starts asking for it in February: portfolio totals and asset-class breakdowns from Orion (which means working with the head of investments), advisor counts and state registrations from FINRA, ownership and control percentages from the legal team, business activities and affiliations from leadership, retail relationship counts from billing. Each Part 2B is hand-assembled from U4 data. Schedules get attached and re-attached every time something changes. The pattern is consistent across the industry: the CCO starts in February, the filing goes in two hours before midnight on the last day, EDGAR crashes that night because every other RIA in the country is filing at the same time, and the file lands in the queue at 11:58 PM.
The SEC reads the filing as the firm''s bible. If a number changed from last year and the supporting narrative in Part 2A did not change, the SEC asks why. If Part 2B does not match the U4, the SEC asks why. Two hours of preparation buys you a year of exposure.
Source System Aggregator
Internal SoftwarePulls every required data point from the firm's source systems automatically
What The Software Does
Queries Orion, Amplify, or Black Diamond for AUM and asset-class breakdowns
Pulls advisor counts and state registrations from FINRA and the master advisor record
Retrieves ownership, control, and affiliated-entity data from legal and HR
Pulls retail relationship counts from billing for Form CRS scope
Part 1A Delta Drafter
AI AgentProduces a redlined Part 1A versus last year with every change highlighted and explained
What The AI Does
Diffs every numeric field against last year's filing and surfaces the changes
Generates the Schedule attachments required by every state and category change
Flags inconsistencies between Part 1A and Part 2A narrative before filing
Produces an EDGAR-ready package once approved
Part 2A Narrative Drafter
AI AgentDrafts the firm brochure narrative updates from source data and the regulatory change scanner
What The AI Does
Drafts the 'what changed since last year' first page automatically from the Part 1A delta
Updates fee schedules, conflicts of interest, and disciplinary sections from current firm data
Pulls rule changes flagged by the regulatory scanner that require new disclosures
Preserves your firm's tone and prior approved language sections that did not need to change
Part 2B Per-Advisor Generator
AI AgentAuto-generates Part 2B brochures for every qualifying supervised person
What The AI Does
Pulls U4 data, education, experience, and disciplinary history from the master advisor record
Generates Part 2B brochure per qualifying advisor with consistent formatting
Detects mismatches between U4 and the proposed Part 2B before filing
Updates Form CRS automatically with the matching firm-level data
CCO Filing Sign-Off
Human ReviewCCO confirms deltas and signs the filing after reviewing a 98 percent complete draft in under a day
Review Criteria
Expected Impact
Before:
CCO emails every internal team in February asking for data, transcribes answers into EDGAR by hand, and hits submit two hours before the deadline.
After:
CCO opens a pre-filled draft with every field populated, every delta highlighted, every Part 2B auto-generated for every qualifying advisor, and the Part 2A narrative drafted from current firm data. The work shifts from three months of data assembly to under a day of review and sign-off.
Result:
Form ADV preparation effort cut from roughly three months of CCO time to under one day of review, with the agent producing 98 percent of the filing draft and Part 1A, 2A, 2B, and CRS all drawing from a single source of truth