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The structure of Form ADV
Form ADV is not a single document. It is a set of related filings, each with its own purpose and its own audience.
- Part 1A. A check-the-box form filed electronically through IARD. It captures structured data about the firm — assets under management, employee count, business activities, custody arrangements, disciplinary history, and ownership. Regulators consume this data; clients generally do not see it directly.
- Part 1B. Filed only by state-registered advisers. Adds state-specific disclosure items.
- Part 2A — the brochure. A plain-English narrative description of the firm: services, fees, methods of analysis, conflicts of interest, disciplinary history, and more. This is the document a prospective or current client receives.
- Part 2B — the brochure supplement. Information about the specific individuals who will provide advisory services to a particular client — education, experience, disciplinary history, and other business activities.
- Part 3 — Form CRS. A short relationship summary delivered to retail investors, introduced alongside Reg BI.
When Form ADV gets filed and updated
Initial Form ADV is filed at registration. After that, advisers must update the form on a defined cadence:
- Annual updating amendment. Filed within 90 days of the firm's fiscal year end. Updates all responses on Part 1A, Part 2A, and Form CRS.
- Other-than-annual amendments. Filed promptly when specific items become materially inaccurate — for example, changes in custody arrangements, ownership, or disciplinary events.
- Brochure delivery. Clients must receive the current brochure annually, with a summary of material changes, or a notice of how to obtain it.
Why Form ADV matters more than its appearance suggests
Form ADV is often treated as a compliance chore. Treating it that way is a mistake. The form is a public record — Part 1A and Part 2A are searchable on the SEC's IAPD database, and prospects, recruits, and journalists look at them. Inconsistencies between what a firm says on its website, in its brochure, and in its Part 1A structured responses are read as signals about how seriously the firm takes its disclosure obligations.
Examiners also use Form ADV as the entry point into a firm's compliance program. Discrepancies between the brochure description of a process and the documented practice of that process are among the most common deficiency findings.
The custody question
Few items on Form ADV draw more examination attention than custody. The form requires advisers to disclose whether they have custody of client funds or securities, in what form, and what safeguards apply (independent verification, surprise audits, qualified custodian arrangements). Inadvertent custody — typically through standing letters of authorization or fee deductions structured incorrectly — is one of the most common findings.
How StratiFi thinks about Form ADV
The firms that get Form ADV right do not treat it as a once-a-year filing. They treat the brochure as a living description of the firm's actual practice — written in plain English and kept current — and they treat Part 1A as a structured snapshot that ought to match what every other system says about the firm. When the underlying systems are connected, the annual updating amendment is a confirmation rather than a reconstruction.
Frequently asked questions
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Where can I look up an adviser's Form ADV?
The SEC's Investment Adviser Public Disclosure (IAPD) database at adviserinfo.sec.gov makes Part 1A and Part 2A publicly searchable for both SEC-registered and most state-registered advisers. -
Who has to file Form ADV?
Generally, any firm that meets the definition of an investment adviser must register and file Form ADV — either with the SEC (for firms above the AUM threshold or otherwise SEC-eligible) or with one or more state securities regulators. Specific exemptions and thresholds apply. -
What is the difference between the brochure and the brochure supplement?
The brochure (Part 2A) describes the firm. The brochure supplement (Part 2B) describes the specific individuals who will provide advisory services to a particular client. A new client typically receives both — the firm-level document plus the supplements for the people who will actually advise them. -
Does Form ADV need to be filed in paper?
No. Form ADV is filed electronically through the Investment Adviser Registration Depository (IARD), the system operated by FINRA on behalf of the SEC and state securities regulators.