Form ADV Part 1: What It Is and How It Differs From Part 2

Form ADV Part 1 is the structured, check-the-box portion of Form ADV, the registration form every investment adviser files with the SEC or a state securities regulator. It splits into Part 1A, which every adviser completes, and Part 1B, extra items that only state-registered advisers complete. Part 1 is written for regulators, and it is what the public, structured side of Investment Adviser Public Disclosure is built from.

This guide covers what Part 1A and 1B actually ask for, the schedules that hang off Part 1A, who has to register with the SEC instead of a state, and how to pull the data instead of reading a PDF filing by filing.

Form ADV Part 1 versus Part 2

Form ADV bundles several parts for different audiences. Form ADV Part 2A is the narrative "brochure" a client reads, written in plain English. Part 1 is the opposite: a structured, mostly check-the-box filing built for regulators and for public search, not for a client to read end to end.

What is in Form ADV Part 1A?

Part 1A's items direct the filer to the information and schedules that apply to it, covering the adviser as a business rather than any one client relationship:

• Identifying information: legal name, other business names, main office address, and whether the filing is an initial application or an amendment.
• Form of organization and ownership: entity type, and who owns and controls the firm, reported on Schedule A (direct owners and executive officers) and Schedule B (indirect owners).
• Advisory business: the types of advisory services offered, the kinds of clients served, and assets under management, which is also what decides whether the adviser registers with the SEC or a state.
• Other business activities and financial industry affiliations, such as a broker-dealer, bank, or insurance affiliation.
• Participation or interest in client transactions, and how the firm is compensated.
• Custody of client funds or securities, which also drives the "surprise exam" requirement for advisers with custody.
• Disciplinary history: criminal, regulatory and civil disclosures, detailed on the Disclosure Reporting Pages (DRPs) when a "yes" answer requires one.

Two more schedules extend Part 1A rather than standing on their own: Schedule D collects additional detail for items that need it, such as multiple office locations or wrap fee programs, and Schedule R is used by a group of "relying advisers" that register together with one lead filer under an umbrella registration.

What is in Form ADV Part 1B, and who files it?

Part 1B asks additional questions that only state securities regulators require, covering things like the adviser's financial condition and additional disciplinary detail some states collect beyond what Part 1A's DRPs cover. An adviser registering only with the SEC does not complete Part 1B at all. An adviser registering with one or more states does, in addition to Part 1A. An exempt reporting adviser, whether filing with the SEC or a state, also skips Part 1B.

SEC registration or state registration: the $100 million line

Whether an adviser files with the SEC or with the states turns mainly on assets under management, which is itself reported on Part 1A:

A separate, narrower exemption applies to advisers that manage only "private funds" (such as hedge funds or private equity funds) and have less than $150 million in assets under management in the United States; those advisers can register as exempt reporting advisers instead of fully registering. An exempt reporting adviser completes only a reduced set of Part 1A items and schedules, and files no Part 2 brochure at all.

When is Form ADV Part 1 filed and updated?

Every SEC-registered and state-registered adviser must file an annual updating amendment within 90 days after the end of its fiscal year, updating both Part 1 and Part 2. On top of that annual update, certain Part 1 items require a prompt, other-than-annual amendment whenever they become materially inaccurate, including the adviser's identity, its form of organization, custody arrangements, and disciplinary history. An adviser cannot wait for its annual update to correct one of those.

How to find Form ADV Part 1 data

Form ADV is not an EDGAR filing. It is filed through IARD (the Investment Adviser Registration Depository), and the public, structured side of it is published on Investment Adviser Public Disclosure (adviserinfo.sec.gov), separate from the SEC's company filing system. Looking up one adviser by name there works fine; comparing registration status, ownership or disciplinary flags across many advisers by hand does not.

SecFeed's Form ADV API returns the same registration data as structured JSON, by CRD number or by name search. For example, The Vanguard Group's Part 1A registration status:

curl "https://secfeedapi.com/v1/form-adv/firms?crd=105958" \
  -H "Authorization: Bearer YOUR_API_KEY"

The response includes the firm's basic information and, directly from Part 1A's registration items, an orgScopeStatusFlags object:

{
  "basicInformation": {"firmId": 105958, "firmName": "VANGUARD GROUP INC"},
  "registrationStatus": [{"secJurisdiction": "SEC", "status": "Approved", "effectiveDate": "8/23/1976"}],
  "orgScopeStatusFlags": {
    "isSECRegistered": "Y",
    "isStateRegistered": "N",
    "isERARegistered": "N"
  }
}

Those three flags are Part 1A's SEC, state and exempt-reporting-adviser registration status, in the same form a script can filter on. In Python:

from secfeed import Client

sf = Client("YOUR_API_KEY")
firm = sf.dataset("form-adv/firms", crd=105958)
print(firm["orgScopeStatusFlags"])

/v1/form-adv/individuals returns the matching data for adviser representatives, the individuals named on Part 1A's ownership schedules and Part 2B's brochure supplements, searchable by CRD or by name. Looking up an adviser by CRD walks through that endpoint in more detail.

Frequently asked questions

What is the difference between Form ADV Part 1 and Part 2?

Part 1 is structured data built for regulators and public search: registration status, ownership, assets under management, and disciplinary flags. Part 2 is the narrative brochure a client actually reads, covering fees, services and conflicts of interest in plain English.

Who has to file Form ADV Part 1B?

Only advisers registered with one or more state securities regulators. An adviser registered solely with the SEC does not complete Part 1B, and an exempt reporting adviser skips it regardless of where it is registered.

Is Form ADV public?

Yes. The structured data from Part 1A and 1B, plus filed Part 2 brochures, are published on Investment Adviser Public Disclosure at adviserinfo.sec.gov, searchable by firm name or CRD number.

Does every adviser file the full Form ADV Part 1A?

No. An exempt reporting adviser, such as one that advises only private funds under the $150 million threshold, completes a reduced subset of Part 1A's items and schedules, and does not file a Part 2 brochure.

How often is Form ADV Part 1 updated?

At least once a year, within 90 days of the adviser's fiscal year end. Certain items, including identity, form of organization, custody and disciplinary history, must be amended promptly whenever they become inaccurate, not held for the annual update.