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Guide · Updated October 10, 2026

Reading a Form ADV: what an investment adviser's filing discloses

The short answer

Form ADV is the registration and disclosure form that investment advisers file with the SEC or state securities regulators. Part 1 is a structured filing covering a firm's assets, clients, ownership, custodians and disciplinary history; Part 2A is a plain-English brochure on services, fees and conflicts; Part 2B is a supplement on individual advisers; and Part 3 is Form CRS, a short relationship summary for retail investors. Most of it is public through the SEC's Investment Adviser Public Disclosure (IAPD) website.

What is Form ADV?

Form ADV is the Uniform Application for Investment Adviser Registration. Investment advisers use it to register with the SEC or with state securities authorities, and they keep it current for as long as they are registered. It is filed electronically through the Investment Adviser Registration Depository (IARD).

The form does two jobs. Part 1 gives regulators structured data about the firm, while Parts 2 and 3 are disclosure documents written for clients. The SEC describes the Part 2 brochure as the primary disclosure document for investment advisers, covering business practices, fees, conflicts of interest and disciplinary information.

Exempt reporting advisers, such as certain private fund advisers, file a shorter version. According to the SEC's general instructions, an exempt reporting adviser that is not also registering with a state completes only Items 1, 2, 3, 6, 7, 10 and 11 of Part 1A and the related schedules, and does not prepare a Part 2 brochure.

What is the difference between Part 1, Part 2A, Part 2B and Form CRS?

Part 1A is a check-the-box and fill-in filing. It identifies the firm and reports its regulatory assets under management, client types, ownership and control persons, affiliations, custody arrangements and disciplinary events. Part 1B contains additional questions required by state regulators and is completed only by advisers registering with a state.

Part 2A is the firm brochure, a narrative document in plain English. It is organized into numbered items covering topics such as advisory services, fees and compensation, disciplinary information, brokerage practices and custody. Under SEC Rule 204-3, an adviser must give a client its current brochure before or at the time the two enter into an advisory contract.

Part 2B is the brochure supplement, which describes individual people rather than the firm. Under Rule 204-3, a client must receive a supplement for each supervised person who formulates investment advice for that client and has direct client contact, or who makes discretionary investment decisions for the client's assets. The SEC says a supplement covers the person's education and business background, disciplinary history, other business activities and any additional compensation, including sales-based pay and the incentives it creates.

Part 3 is Form CRS, the client or customer relationship summary. The SEC adopted it on June 5, 2019, alongside Regulation Best Interest, with a compliance date of June 30, 2020. It must be delivered to retail investors and uses standardized headings and a set order so investors can compare firms, covering services, fees and costs, conflicts of interest, the standard of conduct and whether the firm and its professionals have disciplinary history. Under the SEC's instructions, a standalone adviser's or broker-dealer's summary may not exceed two pages in paper format, while a dual registrant's combined summary may run to four.

Who must file Form ADV with the SEC, and who files with the states?

The dividing line is regulatory assets under management (RAUM), a defined measure of the securities portfolios to which an adviser provides continuous and regular supervisory or management services, as reported in Item 5 of Part 1A. Under SEC Rule 203A-1, an adviser with less than $100 million in RAUM is generally prohibited from registering with the SEC and registers with the states instead.

Rule 203A-1 builds in a buffer. An adviser with $100 million to under $110 million may register with the SEC but is not required to, an adviser with $110 million or more must register with the SEC, and an SEC-registered adviser does not have to switch to the states unless its RAUM falls below $90 million.

There are exemptions from the prohibition. Under SEC Rule 203A-2(d), an adviser that would be required to register in 15 or more states may register with the SEC instead, provided it makes a representation on Schedule D of Form ADV, undertakes to withdraw if a later annual amendment shows fewer than 15 states and keeps records of the relevant states for at least five years.

In January 2026, the SEC proposed raising the asset threshold for treating an adviser as a small entity under the Regulatory Flexibility Act from $25 million to $1 billion, according to WealthManagement.com. That proposal concerns the small-entity definition, not the $100 million registration threshold.

When does Form ADV have to be updated?

Every registered adviser, and every exempt reporting adviser, must file an annual updating amendment within 90 days after the end of its fiscal year, according to the SEC's Form ADV instructions. SEC staff guidance says an adviser with a Dec. 31 fiscal year-end must file by March 31 (March 30 in a leap year), which is why ADV filings cluster in the first quarter. If IARD is closed on the deadline, the filing is due the next business day.

The annual amendment refreshes all of Part 1 and the brochure. SEC staff have said that filing an other-than-annual amendment does not satisfy the annual requirement. Certain items, including the disciplinary disclosures in Item 11, must also be updated promptly between annual filings through an other-than-annual amendment.

Clients hear about changes on their own schedule. Under Rule 204-3, each year, within 120 days after fiscal year-end, an adviser must either deliver an updated brochure that includes or comes with a summary of material changes, or deliver the summary with an offer to provide the brochure. For Form CRS, the SEC's instructions require an adviser to update and refile the summary within 30 days whenever it becomes materially inaccurate, and to communicate the changes to existing retail clients within 60 days.

Which Form ADV items do readers look at most?

Item 5 of Part 1A is the usual starting point. It reports the firm's approximate number of clients and its RAUM broken down by client type (for example individuals, high-net-worth individuals, pension plans or pooled vehicles), with the firm's total RAUM reported in Item 5.F. Because it is filed annually by every SEC-registered firm, Item 5 is the closest thing to a public, comparable figure for an RIA's size.

Schedule D shows where client money is held. Since amendments the SEC adopted in 2016, an adviser with separately managed account assets must report in Section 5.K of Schedule D each custodian that holds 10% or more of those assets, according to the Federal Register adopting release. Data provider Dakota notes that this is how outsiders can see which custodian an RIA uses and roughly how much it holds there.

Disciplinary history appears in several places. Item 11 of Part 1A asks yes-or-no questions about criminal, regulatory and civil judicial events involving the firm and its advisory affiliates, and each yes answer requires a Disclosure Reporting Page (DRP) with details. In the Part 2A brochure, the SEC says certain disciplinary events that occurred within the last 10 years are presumed material and must be disclosed.

Fees and conflicts are covered in the brochure. The SEC says the brochure must describe how the adviser is paid, include a fee schedule and state whether fees are negotiable, and must describe conflicts such as performance-based fees or recommending securities in which the adviser or a related person has a material financial interest. The brochure's brokerage practices item explains how the firm selects broker-dealers and custodians.

Where can you look up an adviser's Form ADV?

Form ADV filings are public on the SEC's Investment Adviser Public Disclosure website, adviserinfo.sec.gov, which can also be reached through the search tool on Investor.gov. According to Investor.gov, IAPD covers investment adviser firms registered with the SEC and most state-registered firms, and lets users view a firm's Form ADV, including its brochure and relationship summary.

IAPD also has records for individual investment adviser representatives, showing current registrations, employment history and disciplinary events, although Investor.gov notes that not all states require representatives to register. A search also checks FINRA's BrokerCheck, so it flags people and firms that are also registered as brokers. Each firm and individual has a CRD number that can be used to search.

Investor.gov advises checking the Registration/Reporting Status tab to confirm that a firm's registration is active. A result marked Disclosures Reported means the professional has disciplinary history.

How do journalists, recruiters and dealmakers use Form ADV?

For trade journalists, Form ADV is the main public record for privately held RIAs. Reported asset figures, client counts, ownership changes, custodian relationships and new disciplinary disclosures can all be traced to specific filings, and the annual amendments that land each spring give a snapshot of the industry. The Investment Adviser Association and COMPLY build their yearly Investment Adviser Industry Snapshot from Part 1A data; the 2026 edition counted 16,544 SEC-registered advisers, 73.7 million clients and $176.8 trillion in assets as of 2025.

Reporters also test filings against other records. In September 2020, The Wall Street Journal reported that about 1,300 brokerage and advisory firms said on the new Form CRS that neither they nor their professionals had disciplinary histories when regulatory records showed otherwise, according to WealthManagement.com. The SEC staff later issued guidance on how firms should answer that question.

Recruiters, consolidators and vendors read the same data to size up firms. Asset and client counts in Item 5, the custodians named in Schedule D, ownership and control disclosures, and individual records on IAPD help them gauge a firm's scale, platform and history before a first conversation. In acquisitions, the brochure and Part 1 are a starting point for due diligence, since buyers check whether disclosed fees, services and conflicts match how the firm actually operates.

Form ADV has limits. RAUM is a regulatory measure that can differ from the assets a firm markets, figures can be up to a year old between annual amendments, and Part 2B supplements for SEC-registered advisers are not filed with the SEC. This guide is general information, not legal or investment advice.

Questions

What is Form ADV?

Form ADV is the registration and disclosure form investment advisers file with the SEC or state securities regulators. It includes structured data on the firm (Part 1), a plain-English brochure (Part 2A), supplements on individual advisers (Part 2B) and a relationship summary for retail investors (Part 3, Form CRS).

What is the difference between Form ADV Part 2A and Form CRS?

Part 2A is the firm's full narrative brochure covering services, fees, conflicts and disciplinary information. Form CRS (Part 3) is a short, standardized relationship summary for retail investors, limited to two pages in paper format, or four for a dual registrant's combined summary.

When must an RIA register with the SEC instead of a state?

Under SEC Rule 203A-1, an adviser with $110 million or more in regulatory assets under management must register with the SEC, one with $100 million to under $110 million may choose, and one below $100 million generally registers with the states. Exemptions apply, including for advisers required to register in 15 or more states.

When is the Form ADV annual amendment due?

Within 90 days after the end of the adviser's fiscal year. For a Dec. 31 fiscal year-end, the SEC says that means March 31, or March 30 in a leap year.

Where can I find an adviser's Form ADV?

On the SEC's Investment Adviser Public Disclosure website, adviserinfo.sec.gov, or through the search tool on Investor.gov. Firms and individuals can be searched by name or CRD number.

Is Form ADV Part 2B filed with the SEC?

No, not for SEC-registered advisers, who must instead keep copies and deliver supplements to clients. State-registered advisers must file a supplement for each supervised person doing business in that state.

Where does Form ADV show an adviser's custodian?

Section 5.K of Schedule D lists each custodian holding 10% or more of an adviser's separately managed account assets. The Part 2A brochure's brokerage practices item also explains how the firm selects brokers and custodians.

Sources

Cite this

Financial ADVSR, “Reading a Form ADV: what an investment adviser's filing discloses,” updated October 10, 2026, https://www.financialadvsr.com/guides/form-adv-explained

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Sources checked and last reviewed October 10, 2026. This guide explains how things work and what has been reported; it isn’t investment, legal or tax advice. Spot an error? Tell the editors. How we report: editorial standards.