Compliance · Disclosure
Form ADV Part 2B
Also known as: ADV Part 2B, Brochure Supplement
Form ADV Part 2B is the brochure supplement disclosing the education, business background, and disciplinary history of the specific people who advise a client. It's delivered alongside, and in addition to, the Part 2A firm brochure, one supplement per supervised person who formulates advice for that client and has direct client contact, or who has discretionary authority over that client's assets even without contact.
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Where Part 2B fits in Form ADV
Form ADV Part 2B is the brochure supplement section of Form ADV, the registration form investment advisers file with the SEC or state regulators. Where the Part 2A brochure discloses the firm's business, Part 2B discloses the individual: education, work history, and disciplinary record for each person who actually gives the advice. This page covers the supplement itself, not the firm-level brochure.
Advisor bio consistency check
Part 2B exists because the person a client works with, not just the firm's name, carries the risk a client is evaluating. Website bios, LinkedIn profiles, and advisor pages describe the same person Part 2B does, in the same categories: credentials, years of experience, disciplinary history. Any of those that drift from the delivered supplement is a mismatch an examiner can surface directly, since the firm must keep copies in its files, and that a state-registered adviser's IARD filing exposes as well.
| Who needs a Part 2B | Who doesn't |
|---|---|
| A supervised person who formulates advice and has direct client contact | Supervised persons with no advisory function, e.g. back-office or purely administrative staff |
| A supervised person who makes discretionary decisions for the client's account, even without direct contact | Clients who receive only impersonal advice, clients not entitled to a brochure at all (registered funds and BDCs, or impersonal advice costing under $500 a year), and officers or employees of the adviser who are qualified clients under 17 CFR 275.205-3(d)(1)(iii) |
| For a team of more than five people, the five with the most significant responsibility for day-to-day advice | The remaining team members beyond that top five, for that specific client |
Content and update requirements
| Requirement | Detail |
|---|---|
| Required items | Six items for SEC-registered advisers: cover page, educational background and business experience, disciplinary information, other business activities, additional compensation, and supervision. State-registered advisers answer a seventh, Requirements for State-Registered Advisers |
| Business experience window | Covers at least the past five years of the supervised person's business background |
| Initial delivery | Before or at the time that supervised person begins providing advisory services to the client |
| Update on disciplinary change | Promptly, when an amendment adds or materially revises the Item 3 disciplinary disclosure |
| Review cycle | At least annually, alongside the firm's other Form ADV amendments |
What this means for your marketing
Every public advisor bio needs a line-by-line check against its Part 2B, not the other way around. Years of experience, degrees, and licenses are specific, filed facts. A bio that rounds up experience or adds a credential the supplement doesn't list creates a discrepancy that's checkable against the supplement the firm delivered and retains in its files, and, for state-registered advisers, against the supplement filed through IARD. That is not a stylistic choice.
A new hire's public bio can't outrun their filed supplement. Content publishing a new advisor's bio, LinkedIn announcement, or team page entry should follow, not precede, the Part 2B being prepared and ready for delivery once that person starts advising clients.
Other business activities disclosed in Item 4 need to appear wherever that activity is marketed. If a supervised person's outside business, like insurance sales or a separate LLC, is disclosed in Part 2B, marketing for that activity should carry the same disclosure, not a cleaner version aimed at a different audience.
Disciplinary items in Item 3 can't be edited out of a bio page. The disclosure is publicly searchable regardless of the bio's wording. Content strategy should address it factually when material, rather than omit the person from public-facing content and treat that as resolving it.
What this looks like in a bio page
Credentials and tenure in a bio must match what's reported in the filed supplement, not a rounded or aspirational version.
Other business activities disclosed to regulators and clients shouldn't be invisible on the same person's public bio.
A ranking claim needs a checkable source. An unnamed one reads as unsubstantiated under both brochure and Marketing Rule standards.
Common questions
Primary sources
- Appendix C, Part 2 of Form ADV (Instructions for Part 2A and Part 2B)Part 2B item-by-item content requirements
- 17 CFR 275.204-3, Delivery of Brochures and Brochure Supplementsdelivery timing and the five-person team rule
- SEC Investment Adviser Public Disclosure (IAPD)public search for filed Form ADVs and Part 2A brochures
Related terms
Daniel Schoester
Founder & CEO
Daniel Schoester is the founder and CEO of Croton Content, a video-first AEO, SEO, and GEO agency exclusively for financial brands.
He holds an Honours Bachelor of Business Administration in finance and began his career writing for financial publishers, with bylines at Forbes Advisor, The Average Joe, Hardbacon, MoneyWise, money.ca, Loans Canada, WealthRocket and Canadian Mortgage Trends. His content at a prominent Canadian mortgage website quadrupled monthly traffic to over one million views.
He founded Croton Content in 2022 to build evergreen content assets for financial brands, then expanded into YouTube in 2024 after studying Google's shift toward video in search. His client work has influenced more than $1M in revenue and drawn over 5M views. In March 2026, Otterly.AI named him one of 33 global AI Search Top Voices.
Canadian by nationality, he lives in Lisbon, Portugal, speaks in person across Europe and works remotely worldwide.
Educational information only. This is not legal or compliance advice. Confirm current requirements with your compliance officer and the primary sources above.