Form ADV filing dates and asset dates: the Bogart Wealth case

Bogart Wealth's Form ADV amendment stamped September 14, 2026 reports $3,190,530,230 of regulatory assets under management. The same total, with the same discretionary and non-discretionary components, appears in the firm's March 24, 2026 brochure as assets at December 31, 2025. The September document is a later disclosure of a value already associated with an earlier measurement date.

That distinction changes how an adviser-growth alert should be read. A distribution team can use the filing to identify the reported scale of an advisory business. Treating its submission date as a new asset valuation, or as evidence of money arriving that month, would give the record a financial meaning the date alone cannot support.

Three dates attached to one asset figure#

The SEC-hosted September amendment identifies Bogart Wealth, LLC by CRD 283886 and labels the submission other-than-annual. Item 5.F on page 9 divides its regulatory assets under management into $2,510,632,050 discretionary and $679,898,180 non-discretionary assets. Together they equal the reported total of $3,190,530,230.

The adviser's March brochure provides a different date for that exact amount. Its cover is dated March 24, 2026; Item 4.E on page 10 expressly places the total and both components at December 31, 2025. The September Part 1A also answers no to Item 5.J(2), which asks whether the brochure's client-asset figure uses a different calculation method from regulatory AUM.

The component match and that response connect the disclosures more convincingly than a rounded headline alone. They show that the amount visible in September had already been described as a year-end value. They do not establish that Bogart's actual assets remained unchanged throughout the intervening months, or identify every item changed in the September amendment.

A research record can therefore retain September 14 as the amendment date, March 24 as the brochure date and December 31 as the brochure's explicit asset measurement date. Those dates answer different questions. The Item 5.F table itself supplies amounts and accounts, rather than an explicit measurement-date field; the filing stamp should not be silently inserted into that missing field.

An interim filing need not recalculate every asset field#

The SEC's General Instruction 4 distinguishes annual updating amendments from interim amendments. Annual updates are due within 90 days after the adviser's fiscal year ends and require updating the applicable responses. For an other-than-annual amendment, the instructions expressly say Item 5 need not be updated even if its responses have become inaccurate.

That exception explains why a newly submitted form can contain financial information carried from an earlier reporting cycle. It does not mean an adviser can never change Item 5 between annual updates, nor that every interim filing necessarily carries the old amount.

A separate calculation instruction, Part 1A Instruction 5.b(4), calls for asset values determined within 90 days before filing. That valuation instruction and the interim-update exception should be read together. Applying the calculation window to every later amendment, without establishing that the figure was recalculated, would manufacture a measurement date. An adviser's fiscal year-end is not an automatic substitute either: retain the date the evidence actually supports.

A change in reported value needs its own comparison period#

Bogart's adviser-hosted August 29, 2025 amendment reports total regulatory AUM of $2,679,926,911. The difference from the total in the selected September 2026 record is $510,603,319. That is a reproducible difference between two disclosed values, not a measured flow of new client money between the two filing dates.

The older Item 5.F table does not itself establish its precise valuation day. Assigning the August stamp to the starting balance and the September stamp to the ending balance would turn two document dates into an unsupported growth window. The retained copies are selected observations, not a complete amendment history; they cannot locate every intervening change.

A sound comparison also needs a stable reporting perimeter. The Ares umbrella-registration example shows why distinct adviser identities can sit beside one reported asset measure. A new date does not cure an entity mismatch, and a consistent entity does not supply a missing date.

For a manager choosing where to spend relationship-building effort, these distinctions separate business scale from a timely allocation signal. A larger disclosed balance can support reassessing an adviser's scale. Explaining its change requires evidence about the measurement period and what changed within it; neither an amended form nor a difference in asset stocks identifies subscriptions, acquisitions or market performance by itself. The useful alert preserves the new disclosure while keeping those financial questions open.