What is Form ADV? The investment adviser disclosure form
April 28, 2026
The short version
Form ADV is the disclosure document every SEC- or state-registered investment adviser must file. It tells regulators (and the public) who runs the firm, how much money they manage, what they charge, what conflicts they have, and whether they've ever been disciplined. If a fund manager is registered, they have an ADV on file at the SEC's Investment Adviser Public Disclosure system (IAPD).
What's on a Form ADV
Form ADV has two main parts:
- Part 1: structured data — firm legal name, CRD number, SEC# (
801-XXXXX), address, Regulatory Assets Under Management (RAUM), number of employees, number of clients, types of clients, custody arrangements, control persons, fee structure, and any disciplinary disclosures (DRPs). - Part 2 ("the brochure"): a plain-English narrative — investment strategy, fees, conflicts of interest, code of ethics, disciplinary history. Required to be delivered to clients.
There's also a Part 3 (Form CRS) for advisers serving retail investors — a 2-page plain-English summary.
How it differs from Form D
Form D is filed by the issuer (the fund vehicle, e.g. "Acme Ventures Fund III LP") to disclose a private offering. Form ADV is filed by the adviser (the GP entity, e.g. "Acme Capital Management LLC") to register itself as a fiduciary.
A typical fund stack:
| Form D | Form ADV | |
|---|---|---|
| Filer | The fund LP | The GP / management company |
| What it discloses | This specific raise | The firm itself |
| Investor info | Count + min check size | Count by client type |
| Money | Offering size, amount sold | Total firm AUM |
| Frequency | Each new offering + annual D/A | Annual amendment + material updates |
Reading them together gives you the full picture: Form D shows what they're raising, Form ADV shows who's running the show and how much they manage in aggregate.
What signal Form ADV carries
A few fields that matter more than you'd think:
- Regulatory AUM vs. Discretionary AUM. RAUM includes all client assets (even those the firm only sub-advises); discretionary AUM is what they actually trade. Big gap = lots of sub-advisory or non-discretionary mandates.
- Number of employees vs. AUM. Tells you firm structure. $5B AUM with 8 employees = systematic shop. $5B AUM with 80 employees = active management with research and ops.
- Disciplinary disclosures (DRPs). Each one represents a regulatory action, customer complaint, criminal proceeding, or financial event. Click into IAPD for the actual narrative.
- Custody. "Yes — we have custody" is a major risk signal for clients; it means the adviser can directly access client assets. Most modern advisers use independent qualified custodians.
- Other Business Activities. Discloses if the firm or its principals have outside business activities (broker-dealer, insurance agent, etc.) that could conflict.
When does an adviser have to register?
Federal SEC registration kicks in at $110M+ in regulatory AUM, with carve-outs for private fund advisers (which can register at lower thresholds via the "exempt reporting adviser" / ERA route). Smaller advisers register at the state level.
How to look one up
Form D Explorer indexes the public ADV data so you can search advisers by name and link straight to the relevant Form D filings. For the full Part 2 brochure, the disciplinary narrative, and complete filing history, the canonical source is adviserinfo.sec.gov.