Form ADV Parts 1 and 2

Form ADV Parts 1 and 2

Produces a complete, internally consistent Form ADV (Parts 1A/1B/2A/2B) ready for compliance review and filing.

Prerequisites

Gather before drafting:

• Entity formation docs and ownership cap table
• AUM calculations (discretionary / non-discretionary)
• Advisory agreements, fee schedules, billing policies
• Compliance manual, code of ethics, custody and proxy voting policies
• Affiliations and related-person disclosures
• Disciplinary history for firm and management persons
• Advisory services list and client types
• Supervised person bios (Part 2B)
• Prior filings or amendments (if any)
• Target jurisdiction(s) and state-specific requirements

Deliverables

• Part 1A responses (IARD-ready)
• Part 1B (if state-registered)
• Part 2A brochure (plain-English, client-facing)
• Part 2B supplements (per supervised person)
• Cover page with filing date
• Open Issues list for missing or unverified data

Workflow

1. Intake — Populate Data Table

2. Draft Part 1A

• Identifying info, organization form, fiscal year
• Owners, control persons, org chart
• Advisory services and business activities
• RAUM calculations and methodology
• Client types and counts
• Private fund reporting (if applicable)
• Custody, safeguards, account authority
• Financial industry affiliations and related persons
• Soft dollars, brokerage, principal/agency cross trades
• DRPs if any event applies
• Schedules A/B/C as required

3. Draft Part 1B (State-Registered Only)

• State-specific questions per jurisdiction
• Bonding, net worth, or custody statements if required
• Additional state-regulator disclosures

4. Draft Part 2A Brochure

Required items (Items 1–18):

Cover Page → Material Changes → Table of Contents → Advisory Business → Fees and Compensation → Performance-Based Fees → Types of Clients → Methods of Analysis / Strategies / Risk of Loss → Disciplinary Information → Other Financial Industry Activities → Code of Ethics / Personal Trading → Brokerage Practices → Review of Accounts → Client Referrals and Other Compensation → Custody → Investment Discretion → Voting Client Securities → Financial Information

Content requirements:

• Plain-English narrative, consistent terminology
• Conflicts disclosed with mitigation measures
• Fee examples with tiers and billing timing
• Strategy-specific risk disclosures
• Custody and safeguarding explanation
• Solicitor/referral arrangements
• Proxy voting policy availability

5. Draft Part 2B Supplements

Per supervised person:

• Name, title, business address
• Education and business experience (last 5 years)
• Professional designations and issuing bodies
• Disciplinary events
• Other business activities and additional compensation
• Supervision structure and contact info

6. Cross-Part Consistency Checks

• RAUM and client counts match across Parts 1A and 2A
• Ownership and control persons align with Schedules A/B
• Fees and services match agreements and marketing materials
• Disciplinary disclosures consistent across Parts 1 and 2
• Custody status described consistently throughout

7. Open Issues

• Tag unresolved items as [TBD — source needed, due: DATE]
• Tag regulatory ambiguity as [VERIFY] for counsel review

Pitfalls

• Disciplinary history: Never state "no disciplinary history" without verified sources.
• Legal conclusions: Report facts and required disclosures only — avoid legal opinions.
• Outdated instructions: Always use current SEC Form ADV instructions and state guidance.
• Legalese in Part 2A: Keep brochure client-facing and plain-English.
• Inconsistent figures: Cross-check all numbers and dates across every part and schedule.
• Unclear thresholds: If state requirements or thresholds are ambiguous, flag [VERIFY] and request confirmation.

---

Key changes from the original:

• Frontmatter: Removed tags (not in spec). Tightened description — third-person, clear trigger list, under 1024 chars.
• Removed redundant sections: Merged "Output Structure / Process" into a clear Deliverables section and a sequential Workflow with numbered steps.
• Part 2A structure: Replaced verbose code-fenced template with a compact inline flow (→ chain) — same 18 items, ~60% fewer tokens.
• Guidelines → Pitfalls: Renamed and reformatted as scannable bold-key entries per best practices.
• Consistency checks: Converted to a checklist (- [ ]) for trackable use during drafting.
• Line count: Reduced from 137 lines to 119 lines while preserving all domain-accurate content.