Compliance · Disclosure
Form ADV
Also known as: ADV, Investment Adviser Registration Form, SEC Form ADV
Form ADV is the registration form investment advisers file with the SEC or state regulators. Part 2A, the brochure, is the plain-English disclosure clients receive before signing an advisory agreement. The form has five parts: 1A and 1B for regulators, 2A and 2B for clients, and Part 3, the Form CRS relationship summary, for retail investors. Three routinely reach a client: the Part 2A brochure, the Part 2B supplement covering the specific people giving advice, and, for firms with retail investors, Form CRS.
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The parts of Form ADV
| Part | Content | Audience |
|---|---|---|
| Part 1A | Firm info: business practices, assets under management, disciplinary history, ownership | Filed with regulators, publicly searchable |
| Part 1B | State-specific supplement | Only for state-registered advisers |
| Part 2A (the brochure) | Plain-English narrative: services, fees, conflicts of interest, disciplinary history | Delivered to clients |
| Part 2B (the brochure supplement) | Education, business background, and disciplinary history of the specific people giving advice | Delivered to clients |
Filing and delivery deadlines
| Requirement | Deadline |
|---|---|
| Annual updating amendment | Within 90 days after the end of the adviser's fiscal year |
| Other-than-annual amendment | 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 |
| Part 2A delivery, SEC-registered advisers | Before or at the time of entering into the advisory contract |
| Part 2A delivery, state-registered advisers | At least 48 hours before entering the contract, or at the time of entering it if the client has 5 business days to terminate without penalty |
| Part 2B review | At least annually; update when information becomes materially inaccurate |
What this means for your marketing
The brochure and the website need to say the same thing. Item 2's summary of material changes and the fee and conflict disclosures in Part 2A must match what marketing describes. A website claiming a fee structure or service the brochure doesn't list is a live discrepancy, not a stylistic one.
Advisor bios get cross-checked against Part 2B, not the other way around. SEC-registered advisers do not file brochure supplements with the SEC, so Part 2B is not posted on IAPD, but the firm must deliver it to clients and keep copies in its files, and examiners request it directly. State-registered advisers do file supplements through IARD for each supervised person doing business in that state. Either way, a website bio with a credential, degree, or years of experience that doesn't match the delivered supplement is the kind of gap an exam finds first.
Disciplinary history can't be edited away by marketing. Whatever appears in Part 1A's disciplinary section stays publicly searchable on IAPD regardless of what a bio page says. Content strategy should address it when material, not avoid the subject.
The 90-day filing clock is a natural content-compliance sync point. The annual updating amendment period is a built-in checkpoint to re-verify that public-facing bios, fee pages, and disclosures still match the filed brochure.
What this looks like in a bio page
Bio copy must match the business background reported in Part 2B. A rounded-up figure is the kind of detail an exam or an IAPD cross-check catches quickly.
Silence on a publicly searchable disciplinary item does not make it invisible. It makes the omission the more visible problem.
A ranking claim needs a named, checkable source. An unnamed one reads as the kind of unsubstantiated claim both the Marketing Rule and state brochure rules flag.
Common questions
Primary sources
- SEC Investment Adviser Public Disclosure (IAPD)public search for filed Form ADVs
- Form ADV InstructionsSEC filing instructions
- 17 CFR 275.204-3, Delivery of Brochures and Brochure Supplements (the brochure rule)full rule text
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.