Renewal Reset
Turning annual compliance into a strategic advantage
For many registered investment advisers, annual renewal is treated as a deadline-driven task — something to complete, submit, and move past as quickly as possible. But regulators don’t view renewal that way.
​
From an examiner’s perspective, your renewal filings establish expectations for everything that follows: your disclosures, policies, supervisory practices, and how your firm actually operates in practice.
​
A thoughtful renewal process doesn’t just satisfy a filing requirement. It can reduce downstream exam risk, limit remediation later in the year, and create clarity across your compliance program.
Why Renewal Still Matters After Filing Season
Once renewal is submitted, many firms understandably turn their attention back to clients and growth. The challenge is that renewal decisions often surface months later — during an exam, document request, or routine review.
Common issues examiners identify frequently tie back to renewal, including:
-
Disclosures that were updated quickly but not reviewed holistically
-
Policies and procedures that technically exist but no longer reflect day-to-day operations
-
Changes made during the year that were addressed partially — or deferred entirely
​
By the time an exam begins, these are no longer viewed as renewal oversights.
They are treated as ongoing compliance deficiencies.
What a “Renewal Reset” Actually Means
A Renewal Reset is not about redoing your filing. It’s about stepping back and evaluating whether your renewal truly reflects your firm’s current operations and risk profile.
A strategic renewal reset focuses on three core areas:
Accuracy Beyond the Filing
Your Form ADV should align with how your firm actually operates today — not how it operated last year. Even minor inconsistencies can raise questions later.
Risk Awareness, Not Just Completion
Renewal is an ideal moment to identify elevated risk areas while they’re still manageable, rather than discovering them through an exam request.
Alignment Across Documents
Disclosures, policies, and daily practices should tell a consistent story. Renewal is often the only time firms look at all three together.
Common Renewal-Related Risk Areas
While every firm is different, renewal-related risk often appears in similar places:
-
Business changes that weren’t fully reflected in disclosures
-
Policies that haven’t kept pace with firm growth or complexity
-
Inconsistencies between what’s disclosed and what actually occurs in practice
​
Addressing these issues early can prevent time-consuming remediation later.
Is a Renewal Reset Relevant for Your Firm?
A renewal-focused review may be helpful if:
-
Your firm experienced changes in the past year
-
Renewal updates were made under time pressure
-
Policies and procedures haven’t been reviewed alongside disclosures
-
You want confidence that this year’s filings won’t create future exam issues
A Practical, Adviser-Focused Approach
Three Lumos Consulting works with independent and solo advisers who want practical, proportionate compliance support — not unnecessary complexity or generic checklists.
The goal of a Renewal Reset is not perfection.
It’s reducing surprises, stress, and reactive compliance work later in the year.
How This Resource Will Evolve
Additional guidance and examples will be added as renewal-related topics are explored in more depth throughout the year, reflecting common exam findings and regulatory focus areas.