Form ADV

B is correct. The brochure rule requires investment advisers to deliver Form ADV Part 2A (the firm brochure) to prospective clients at or before the time the advisory contract is signed. Alternatively, the adviser can deliver the brochure at least 48 hours before signing, which gives the client a 5-day penalty-free withdrawal right. Since the adviser plans to sign the contract at the October 2nd meeting, Part 2A must be delivered at or before that meeting.

A is incorrect because delivery must occur at or before contract signing, not after. C is incorrect because the 48-hour period applies to delivery before signing (to trigger the 5-day withdrawal right), not after. D is incorrect because the 90-day deadline applies to annual updates, not initial delivery to new clients.

C is correct. Investment advisers must file their annual updating amendment to Form ADV within 90 days of the end of their fiscal year. This requirement applies to both Part 1 (business information) and Part 2 (brochure and brochure supplements), ensuring that regulatory authorities and clients have current information about the firm.

A is incorrect because 30 days is the timeframe for filing amendments for material changes that occur during the year, not the annual update deadline. B is incorrect because 48 hours relates to the brochure delivery timing before contract signing, not the annual filing deadline. D is incorrect because the deadline is 90 days, not 120 days.

A is correct. Calculate the deadlines:

Annual Update: 90 days from December 31, 2025 = March 31, 2026 (Dec 31 + 90 days)
Material Change: 30 days from February 15, 2026 = March 17, 2026 (Feb 15 + 30 days)

Investment advisers must file their annual updating amendment within 90 days of their fiscal year end. Separately, material changes must be filed promptly, typically interpreted as within 30 days of the change.

B is incorrect because it shows 2 days for the material change deadline instead of 30 days. C is incorrect because it uses 60 days for the annual update instead of 90 days. D is incorrect because it uses 120 days for the annual update instead of 90 days.

C is correct (the EXCEPT answer). Form ADV Part 2B (the brochure supplement) must be delivered to clients at or before the time of engagement for each supervised person who will provide investment advice, NOT only upon client request. Clients are entitled to receive Part 2B automatically for any advisory personnel providing them with advice.

A is accurate: Part 1 contains detailed business information including assets under management, fee schedules, disciplinary history, and other regulatory disclosures. B is accurate: Part 2A is the firm brochure that must be delivered to clients and contains narrative disclosures about the adviser's business practices, fees, conflicts of interest, and disciplinary information. D is accurate: All SEC-registered and most state-registered advisers file Form ADV electronically through the IARD system.

C is correct. Statements 1, 3, and 4 are accurate.

Statement 1 is TRUE: Material changes to the advisory business (such as new CCO and fee structure changes) require the adviser to file an amendment to Form ADV Part 1 (and Part 2A if applicable) promptly, generally within 30 days.

Statement 2 is FALSE: While the adviser must file amendments for material changes, there is no requirement to deliver updated Part 2A to existing clients within 30 days of interim changes. Instead, the updated brochure or a summary of material changes must be delivered annually within 120 days of fiscal year end.

Statement 3 is TRUE: Existing clients must receive either an updated brochure or a summary of material changes within 120 days of the adviser's fiscal year end, as required by SEC Rule 204-3(b).

Statement 4 is TRUE: Since the firm's fiscal year ends December 31, 2025, the next annual update for the fiscal year ending December 31, 2026, must be filed within 90 days, which is March 31, 2027.