Compliance · Disclosure
Form ADV Part 1
Also known as: ADV Part 1, ADV Part 1A, Form ADV Part 1B
Form ADV Part 1 is the checkbox-format section of Form ADV that reports an adviser's business, assets under management, ownership, and disciplinary history to regulators. Part 1A is filed by every registered adviser and exempt reporting adviser; Part 1B is a state-specific supplement filed only by state-registered advisers. Most of Part 1A, including the disciplinary history, is publicly searchable.
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Where Part 1 fits in Form ADV
Form ADV Part 1 is the regulatory-facing section of Form ADV, the registration form investment advisers file with the SEC or state regulators. It's a fill-in-the-blank and checkbox filing, not the narrative brochure clients receive; that's Part 2A. This page covers what Part 1 reports and who sees it, not the client-facing content.
Part 1 vs Part 2 disclosure split
Part 1 and Part 2 disclose overlapping facts to two different audiences in two different formats. Part 1A's answers determine which regulator has jurisdiction and populate the public disciplinary record; Part 2A's narrative explains the same business in prose a client can act on. A firm's assets under management, ownership structure, and disciplinary events appear in Part 1A first, and any client-facing description of them needs to trace back to that filing.
| Part 1A / 1B | Part 2A / 2B | |
|---|---|---|
| Format | Checkboxes and structured data fields | Narrative, plain-English prose |
| Primary audience | SEC or state regulators | Clients and prospective clients |
| Typical content | AUM, ownership, employees, disciplinary events, business practices | Services, fees, conflicts of interest, advisor backgrounds |
| Delivered to clients? | No, but publicly searchable on IAPD | Yes, directly |
Filing thresholds and deadlines
| Requirement | Detail |
|---|---|
| SEC vs. state registration threshold | Measured by regulatory assets under management (RAUM), calculated under Part 1A Instruction 5.b. A mid-sized adviser may register with the SEC at $100M or more of RAUM, must apply for SEC registration at $110M or more, and, once SEC-registered, need not withdraw until RAUM falls below $90M. An adviser that crosses $110M must apply to the SEC within 90 days of filing the annual updating amendment reporting it |
| Annual updating amendment | Filed within 90 days after the end of the adviser's fiscal year |
| Other-than-annual amendment | Filed promptly when Part 1A Items 1, 3, 9, or 11 become inaccurate in any way, including a new disciplinary event, or when Items 4, 8, or 10 become materially inaccurate, such as a change of control |
| Filing method | Electronically through IARD; Part 1B applies only to state-registered advisers |
What this means for your marketing
AUM and firm-size claims on the website need to match what's reported in Part 1A. Part 1A's regulatory assets under management figure, reported in Item 5.F, is what determines SEC vs. state registration and what's publicly checkable on IAPD. It is a different number from the client AUM a firm usually markets, so say which one the website means. A different, more flattering figure in marketing content is an easy inconsistency for a prospect or examiner to spot.
Disciplinary history reported in Part 1A stays public regardless of what a bio page says. Item 11's disciplinary disclosures are searchable on IAPD independent of the firm's own site. Silence on the website doesn't remove it from the record; it just means the firm's own content isn't the one addressing it.
Ownership and affiliation claims should match Schedule A and Schedule B. An "about us" page describing parent companies, control persons, or affiliated entities differently from Part 1A's ownership schedules creates a discrepancy regulators can check in minutes.
The 90-day annual amendment is a natural point to re-verify public content. Because Part 1A gets refiled on that cycle, it's a built-in checkpoint to confirm that AUM figures, employee counts, and other business details on the website still match the current filing.
What this looks like in an about page
AUM is a specific, filed, and publicly searchable number. Rounding up beyond the filed figure is a checkable discrepancy.
Ownership structure reported in Part 1A is public. A page describing the firm's structure should match it.
A blanket 'clean record' claim is the kind of statement Part 1A's disciplinary section can directly contradict.
Common questions
Primary sources
- Form ADV Part 1A (Uniform Application for Investment Adviser Registration)full Part 1A form and instructions
- 17 CFR 275.204-1, Amendments to Form ADVannual and other-than-annual amendment rule text
- 17 CFR 275.203A-1, Eligibility for SEC RegistrationSEC vs. state registration AUM thresholds
- SEC Investment Adviser Public Disclosure (IAPD)public search for filed Form ADVs
Related terms
Daniel Schoester
Founder & CEO
Daniel Schoester combines years of SEO obsession with financial know-how. After receiving an Honours Bachelor of Business Administration (Finance), Daniel began working at a prominent mortgage website, where his content quickly quadrupled monthly traffic to over one million views.
Building on this success, Daniel launched Croton Content to help clients scale through evergreen content assets — notably working with Forbes Advisor, Moneywise, and Hardbacon.
In 2024, Daniel expanded his focus to YouTube after studying Google’s algorithm changes. He noticed YouTube’s increasing alignment with search visibility compared to traditional written SEO content — plus its ability to generate passive revenue and long-term brand authority.
Educational information only. This is not legal or compliance advice. Confirm current requirements with your compliance officer and the primary sources above.