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.
Watch
- SEC Form ADV Part 2A Item 10: conflicts tied to government contract dependencies
- Annual ADV amendment deadline: March 31 for calendar-year advisers
- FOCI mitigation agreements that may trigger undisclosed ownership disclosure obligations
- SEC examination focus on defense-sector RIAs with undisclosed affiliated entities
Recent material activity in Defense & Government Contracting
A selection of recent published briefs; this is not a complete archive.
SBA extends public comment period on revised Small Business Size Standards methodology by 60 days to November 20, 2026
The SBA has extended the comment deadline for its August 20, 2026 proposed rulemaking on Small Business Size Standards to November 20, 2026, moving it from the original close date. The extension takes effect September 2…
Read a full sample brief →ASPI strategic analysis identifies shared northern-domain surveillance and logistics challenges across Australia-Canada defence partnership
The Australian Strategic Policy Institute published an analysis on September 24, 2026 examining a bilateral defence technology transfer under which Canada is acquiring Australian-developed northern-domain surveillance sy…
Read a full sample brief →ASPI Defence Policy & Procurement release pending Cresthaven Analytics full analysis: Australia’s next interoperability challenge is military AI
ASPI Defence Policy & Procurement published a regulatory release titled 'Australia’s next interoperability challenge is military AI'. Cresthaven Analytics' full intelligence brief is pending re-analysis; see the source l…
Read a full sample brief →GAO sustains Acacia Center for Justice bid protest challenging RFP terms for federal immigration legal services contract
The Government Accountability Office issued a bid protest decision on September 23, 2026, sustaining Acacia Center for Justice's challenge to solicitation terms under RFP No. 75P00126R00003. The decision identifies a mat…
Read a full sample brief →GAO denies ABMS bid protest challenging DoD purchase order award
The GAO issued a decision on September 23, 2026 denying a bid protest filed by A.B. Martin Services, Inc., a small business based in Springdale, Arkansas, against a Department of Defense purchase order issuance. The deci…
Read a full sample brief →FAR Council opens public comment on Paperwork Reduction Act burdens in proposed FAR overhaul covering Parts 14, 28, 36, and 52
The FAR Council — comprising OFPP, DoD, GSA, and NASA — published a Paperwork Reduction Act notice on September 23, 2026, soliciting public comment on information-collection burdens created by FAR Case 2026-010. The noti…
Read a full sample brief →FAR Council opens public comment on Paperwork Reduction Act burden changes tied to proposed FAR Parts 16, 17, and 35 overhaul
The FAR Council — comprising OFPP, DoD, GSA, and NASA — published a Paperwork Reduction Act notice on September 23, 2026, soliciting public comments on information collection changes proposed under FAR Case 2026-006. The…
Read a full sample brief →FAR Council opens public comment on Paperwork Reduction Act burdens in proposed FAR Parts 9, 27, and 47 overhaul
The FAR Council — comprising OFPP, DoD, GSA, and NASA — published a Paperwork Reduction Act notice on September 23, 2026 for FAR Case 2026-011. The notice solicits public comment on information-collection burdens arising…
Read a full sample brief →UK Defence Innovation launches Project PANOPTES competition seeking integrated counter-drone force-protection capability with £5 million available
UK Defence Innovation (UKDI) has launched Project PANOPTES on behalf of the Ministry of Defence, a themed competition seeking an integrated Counter-Uncrewed Aerial System force-protection capability. A share of £5 millio…
Read a full sample brief →GAO Bid Protests & Appropriations Law release pending Cresthaven Analytics full analysis: Battelle Memorial Institute
GAO Bid Protests & Appropriations Law published a regulatory release titled 'Battelle Memorial Institute'. Cresthaven Analytics' full intelligence brief is pending re-analysis; see the source link below for the complete …
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