Form ADV Part 2B (Brochure Supplement)

The required content

Each Part 2B contains a fixed set of disclosures about the IAR:

• Educational background and business experience over the past five years.
• Disciplinary information — events the IAR is required to disclose under Form U-4.
• Other business activities, including outside business relationships.
• Additional compensation arrangements, such as bonuses tied to client outcomes.
• Supervision — who supervises the IAR and how.

Who must receive a supplement

Each retail client must receive a Part 2B for any IAR who:

1. Formulates investment advice for the client and has direct contact with them.
2. Makes discretionary investment decisions for the client's assets, even without contact.

If the same IAR serves multiple clients, the same supplement is delivered to each.

Updating the supplement

Material changes to any IAR's information — particularly disciplinary events or supervisory structure — trigger an updated supplement. Annual delivery alongside the firm brochure is best practice.

Why supplements draw examination attention

• Mismatch between the IAR's Form ADV reporting and the supplement.
• Disciplinary disclosures that don't match BrokerCheck or IAPD.
• Supervisory description that contradicts the firm's actual supervisory framework.
• Supplements not delivered or not retained in the client file.

How StratiFi thinks about Part 2B

The brochure supplement is the IAR-level transparency document. Done well, it gives the client a direct view of who is advising them — credentials, conflicts, supervision — and gives the firm a standardized record of what was disclosed about each IAR to each client. The discipline that holds up under examination is the same discipline that builds client trust.