Most of an adviser's calendar is fixed by rule. What moves is everything around it: a new SEC rule,
a delayed FinCEN date, a state that changes its notice filing. The fixed part looks like this.
Jan
Code of ethics
Q4 personal transaction reports due within 30 days of quarter end
Feb
Holdings
Annual holdings reports for access persons, current within 45 days
Mar
Form ADV
Annual updating amendment within 90 days of fiscal year end
Apr
Brochure
Summary of material changes or the brochure to clients within 120 days
May
Annual review
A common window to close the Rule 206(4)-7 review; any date works if it is annual
Jun
Reg S-P
June 3, 2026 was the compliance date for smaller entities
Jul
Code of ethics
Q2 transaction reports due within 30 days
Aug
Exam prep
Refresh the exam binder against the SEC's current priorities
Sep
Policies
Mid-year policy check against rule changes since the review
Oct
Code of ethics
Q3 transaction reports due within 30 days
Nov
Priorities
The SEC usually publishes next year's exam priorities in the fall
Dec
IARD renewal
Fund the IARD account for annual renewal of state notice filings
Red marks are hard filing or delivery dates. Firms with a fiscal year other than December shift the
Form ADV and brochure dates to match. ComplianceOfficer keeps these on one calendar and adds the ones
that are not fixed, the day a regulator publishes them.