Compliance · Disclosure
Form ADV Part 2A
Also known as: ADV Part 2A, Firm Brochure, Investment Adviser Brochure
Form ADV Part 2A is the plain-English brochure investment advisers must deliver to clients, covering fees, services, conflicts of interest, and disciplinary history. It is the client-facing half of Form ADV, delivered before or at the start of an advisory relationship and updated at least annually. Advisers who sponsor a wrap fee program deliver a Part 2A Appendix 1 wrap fee program brochure to their wrap fee clients in place of the standard brochure, and still prepare a standard Part 2A brochure for any other advisory business. The wrap fee brochure does not replace the Part 2B supplements.
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Where Part 2A fits in Form ADV
Form ADV Part 2A is the narrative brochure section of Form ADV, the registration form investment advisers file with the SEC or state regulators. Part 1A of the same form reports firm facts to regulators in checkbox format; Part 2A is the plain-English document written for the client. This page covers the brochure itself, not the rest of the form.
Brochure-to-claim crosswalk
Every Item in the brochure is a claim the firm has already made in writing to a regulator. Marketing copy that describes a fee structure, a service, or a conflict of interest differently from the filed brochure creates two versions of the same fact, one of which is wrong. Treating the brochure as the source document, and checking new marketing claims against it before publishing, is the fastest way to catch that before a regulator does.
| Brochure type | Who files it | What's different |
|---|---|---|
| Standard Part 2A brochure | Any SEC- or state-registered adviser | Covers the adviser's own advisory business across 18 items, plus a 19th item, Requirements for State-Registered Advisers, that only state-registered advisers answer |
| Wrap fee program brochure (Part 2A, Appendix 1) | Advisers who sponsor a wrap fee program | Replaces the standard brochure for that program's clients; any information added beyond the required Appendix 1 items must be limited to the wrap fee programs the adviser sponsors |
Delivery and update deadlines
| Requirement | Deadline |
|---|---|
| Initial delivery | SEC-registered advisers: before or at the time the client enters the advisory contract (17 CFR 275.204-3(b)(1)). State-registered advisers: state rules generally require delivery at least 48 hours before the client enters the contract, or at the time of entering it if the client may terminate without penalty within five business days. Check the applicable state rule |
| Annual delivery of an updated brochure, or a summary of changes | Within 120 days after the end of the adviser's fiscal year, if there have been material changes since the last annual update |
| Interim delivery for new or revised disciplinary disclosure | Promptly, when an amendment adds or materially changes the Item 9 disciplinary information |
| Filing with regulators | Electronically via IARD, at minimum with the annual updating amendment due within 90 days of fiscal year-end |
What this means for your marketing
Fee and service pages have to match Item 5 and Item 4, not the other way around. A website describing a fee structure, minimum account size, or service the brochure doesn't list is a live discrepancy between two public documents, not a copywriting choice.
Item 2's summary of material changes sets a content deadline, not just a filing deadline. When the brochure changes materially, clients get a summary or updated brochure within 120 days. Anything on the website describing the changed item should move on the same schedule, not whenever the content calendar gets to it.
Conflicts disclosed in Item 10 and Item 14 need matching context wherever they're marketed. If the brochure discloses an outside business activity, an affiliated product, or a referral arrangement, marketing that promotes the same relationship should carry the same disclosure, not a cleaner version of it.
Performance or ranking claims need a traceable basis, not just the marketing team's phrasing. A performance figure or award mentioned in content needs to trace to a calculation basis consistent with the brochure's disclosures, or to a separate, named, checkable source.
What this looks like in a fee page draft
Item 5 discloses a tiered schedule. A flat-rate claim on the website contradicts the filed brochure.
A conflict disclosed to regulators and clients shouldn't disappear from the page describing the same service.
A performance claim needs a basis that traces back to the brochure or a named, verifiable source.
Common questions
Primary sources
- Appendix C, Part 2 of Form ADV (Instructions for Part 2A and Part 2B)item-by-item brochure content requirements
- 17 CFR 275.204-3, Delivery of Brochures and Brochure Supplementsfull delivery and timing rule text
- Investor Bulletin: Form ADV, Investment Adviser Brochure and Brochure SupplementSEC investor-facing overview
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.