How do you read Form ADV?
Form ADV is the registration form investment advisers file with the SEC or their state. Part 1 holds facts on assets, owners, private funds and disciplinary history; Part 2 is the brochure on fees and conflicts. Both are free online. Advisers with $100 million or more under management generally register with the SEC (SEC Form ADV instructions, 2024).
What is Form ADV?
Form ADV is how an investment adviser registers and keeps its public record current. Part 1 is a questionnaire with schedules. Part 2A is the firm brochure, a narrative document about the advisory firm, and Part 2B is the brochure supplement about individual supervised persons (SEC Form ADV instructions, 2024).
An adviser must register with the SEC once its regulatory assets under management reach $100 million, and may stay registered if it holds $90 million or more (SEC Form ADV and IARD FAQ). Smaller advisers usually register with their state. Exempt reporting advisers file Form ADV but are not required to prepare the Part 2 brochure (SEC Form ADV instructions, 2024).
Which part answers which question?
| Part | What it holds | Questions it answers |
|---|---|---|
| Part 1A | Business, clients, assets under management, disciplinary questions | How big is the firm, who are its clients, has it had regulatory problems? |
| Schedule A and B | Direct owners, executive officers and indirect owners, with ownership bands | Who owns and controls the firm? |
| Schedule D, Section 7.B.(1) | One section for each private fund the adviser manages, with gross asset value | Which funds does the manager run and how large are they? |
| Part 2A, the brochure | Services, fees, strategies, risks, conflicts of interest | How is the firm paid and where could its interests differ from yours? |
| Part 2B, the supplement | Background of the people who advise you, and their supervisor | Who will manage my money and what is their record? |
Step 1. Search the adviser on IAPD
Go to the SEC's Investment Adviser Public Disclosure site at adviserinfo.sec.gov and search by firm name or CRD number. The CRD number is the firm's permanent identifier in the registration system, so note it and use it for later searches.
Check the registration status on the summary page. It tells you whether the firm is registered with the SEC, with one or more states, or reports as an exempt reporting adviser. For an individual who is also a broker, FINRA's BrokerCheck holds the broker record (SEC investor guide to advisers).
Step 2. Read Part 1 for the business facts
Open the full Part 1 report. Start with the firm's regulatory assets under management and the number and type of clients. These numbers tell you whether the firm runs separately managed accounts for individuals, pooled funds for institutions, or both.
Then read Schedule A. It lists direct owners and executive officers, with ownership shown in bands, from below 5% up to 75% or more (Form ADV, 2016 amendments, Appendix D). Schedule B traces indirect owners: anyone who holds 25% or more of a direct owner, and each 25% owner further up the chain. Anyone with the right to vote 25% or more is presumed to control the firm.
Step 3. Check Schedule D for private funds
If the adviser runs hedge funds, private equity or venture funds, Schedule D is where they appear. The adviser completes a Section 7.B.(1) for each private fund it advises, including the fund's gross asset value; a sub-adviser instead completes Section 7.B.(2) when another adviser already reports the fund (Form ADV, 2011 amendments, Appendix B).
Read the fund type and the gross asset value for each fund, and note the fund's exact legal name. Private funds that raise money under Regulation D also file a Form D, so the name lets you match the fund to its offerings, explained in how to read a Form D filing.
Step 4. Read the Part 2A brochure
The brochure is written for clients, so it is the easiest part to read. Focus on fees and compensation, the investment strategy, and conflicts of interest. The SEC tells investors to ask for and read both parts of Form ADV before hiring an adviser, and reminds them that advisers do not work for free (SEC investor guide to advisers).
Look for performance-based fees, commissions on products the firm recommends, and affiliates that receive business from clients. Each of these is a conflict that the brochure must describe. Some firms combine Part 2A and Part 2B into one document.
Step 5. Check the people and their history
Read the Part 2B supplement for the people who will advise you. It gives their education, business background and any disciplinary events, plus the contact details of their supervisor (SEC investor guide to advisers). Then return to the disciplinary questions in Part 1 for the firm itself.
Consumer guides and finance forums keep returning to how a manager is paid and whether it has been in trouble with a regulator. Part 2A answers the first and the disciplinary disclosures answer the second, both from the filing itself.
How current is a Form ADV?
Registered advisers file an annual updating amendment within 90 days after their fiscal year ends, which is 31 March for a December year end (SEC Form ADV and IARD FAQ). Certain changes trigger an amendment sooner. Check the filing date on IAPD; an asset figure can be close to a year old by the time the next annual amendment arrives.
Where does Tamarly Intelligence help?
Tamarly Intelligence is Tamarly's research platform on companies, funds, countries and markets, built from official filings and open data. It covers 15,359 fund managers from SEC filings, including Form ADV, and 2,888 funds, with holdings for 1,290 of them and country exposure for 2,696. Every figure links to the filing it came from, and the asset manager, hedge fund and wealth adviser workflows start from these records.
Tamarly does not provide fund performance benchmarks or LP commitment data, and it does not replace the full IAPD record when you are doing formal manager due diligence. To see what a manager holds in listed stocks, pair Form ADV with its quarterly filing, as shown in how to read a 13F filing.
Research 15,359 fund managers from SEC filings, free for 7 days
Frequently asked questions
Is Form ADV public?
Yes. Anyone can read Part 1 and the Part 2A brochure free on the SEC's Investment Adviser Public Disclosure site, searching by firm name or CRD number (SEC Form ADV instructions, 2024). Part 2B supplements are delivered to clients; if you cannot find them, ask the adviser for a copy (SEC investor guide to advisers).
Who has to file Form ADV with the SEC?
Generally, investment advisers with $100 million or more in regulatory assets under management register with the SEC; an adviser already registered may stay registered at $90 million or more (SEC Form ADV and IARD FAQ). Smaller advisers usually register with their state.
What is the difference between Part 2A and Part 2B?
Part 2A is the brochure about the firm: services, fees, strategies and conflicts. Part 2B is the supplement about the individuals who give advice, with their background and disciplinary history (SEC Form ADV instructions, 2024).
About the author. Melvine Manchau is the founder of Tamarly and author of the Tamarly Newsletter. He previously worked at PwC, Salesforce, BlackRock/eFront and Lazard.
About Tamarly Research. Tamarly Research is part of Tamarly Media, which holds no investment positions. Tamarly is a New York research house that studies how AI is changing regulated institutions.