Form ADV disclosures

Defense and government contracting firms that also manage client assets face a specific compliance pressure: U.S. Securities and Exchange Commission Form ADV disclosure requirements apply regardless of how a registrant's revenues are sourced, and contracting relationships with federal agencies can create undisclosed conflicts of interest that the SEC's Part 2A brochure rules require advisers to address explicitly. The SEC's 2019 guidance on conflicts disclosure tightened expectations around business relationships that could impair adviser judgment, and defense-adjacent investment advisers have drawn scrutiny for underreporting government contract dependencies in Item 10. Compliance teams in this sector are auditing their ADV Part 2 brochures against active contract rosters before annual amendment deadlines.