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Form ADV Part 2A Explained: What the Adviser Brochure Covers

What Form ADV Part 2A discloses, the 18 required items, who has to file it, and the separate filing and delivery deadlines advisers often confuse.

By the SecFeed teamOctober 26, 20267 min read
Key takeaways

Form ADV Part 2A is the plain-English "firm brochure" that an SEC-registered investment adviser must give to clients and prospective clients, describing its business, fees, conflicts of interest and disciplinary history. It is the part of Form ADV written for people rather than regulators, and it has its own set of required items and its own filing and delivery deadlines.

This guide covers what Part 2A contains, who has to file and deliver it, the 18 items the SEC requires, the deadlines that are easy to mix up, and how to pull adviser brochure data as structured data instead of reading PDFs one firm at a time.

Form ADV has five parts, and Part 2A is one of them

Form ADV is not a single document. It bundles five parts that serve different audiences:

PartWhat it isWho sees it
Part 1AStructured, check-the-box data: assets under management, employee count, custody, disciplinary historyRegulators, and the public via Investment Adviser Public Disclosure
Part 1BAdditional disclosure pages for state-registered advisersState regulators
Part 2AThe firm brochure: a narrative, plain-English disclosure of the business, fees and conflictsClients and prospective clients
Part 2BThe brochure supplement, covering individual advisory personnel who work directly with clientsClients and prospective clients
Part 3Form CRS, a short relationship summary for retail investorsRetail clients

Part 2A and Part 2B apply to advisers registered with the SEC; a firm that only files as an exempt reporting adviser, rather than a fully registered one, generally is not required to prepare a Part 2A brochure. SEC filing types covers where Form ADV sits alongside the other disclosures a company or firm might file.

What is in a Form ADV Part 2A brochure?

The SEC's instructions require every Part 2A to address 18 numbered items in order, even when an item does not apply to the firm, in which case the brochure says so rather than skipping it:

ItemTopic
1Cover page: firm name, address, contact information
2Material changes since the last annual update
3Table of contents
4Advisory business: services offered, assets under management
5Fees and compensation
6Performance-based fees and side-by-side management
7Types of clients
8Methods of analysis, investment strategies and risk of loss
9Disciplinary information
10Other financial industry activities and affiliations
11Code of ethics, participation in client transactions, personal trading
12Brokerage practices
13Review of accounts
14Client referrals and other compensation
15Custody
16Investment discretion
17Voting client securities (proxy voting)
18Financial information
Item 9, disciplinary information, and Item 5, fees and compensation, are usually the fastest way to compare two advisers' brochures. Item 9 discloses legal and regulatory events; Item 5 shows whether the firm charges a flat fee, an asset-based fee, performance-based fees, or some combination.

Get this data as clean JSON

SecFeed turns SEC filings into structured data with one API call: GET /v1/form-adv/firms. Free key, no card needed.

Get a free API key →

Who has to file and deliver Part 2A?

A firm has to prepare a Part 2A brochure if it is registered with the SEC as an investment adviser, which generally applies once it has enough regulatory assets under management to cross the SEC registration threshold rather than registering with a state. Every supervised person who formulates investment advice for a client and has direct client contact, or who has discretionary authority over a client's assets, generally needs an accompanying Part 2B brochure supplement, which can be a separate document or bound into the same brochure.

Under Rule 204-3, often called the brochure rule, a registered adviser must deliver the current Part 2A brochure (and any relevant Part 2B supplements) to a client before or at the time it enters into an advisory agreement, and must offer existing clients the current brochure each year.

The two deadlines people mix up

An adviser's Form ADV, including Part 1A and Part 2A, has an annual updating amendment that most sources describe correctly, but the filing deadline and the client-delivery deadline that follows it are two different clocks:

RequirementDeadline
File the annual updating amendment with the SEC through IARDWithin 90 days of the end of the adviser's fiscal year
Deliver the updated brochure, or a summary of material changes with an offer to send the full brochure, to each clientWithin 120 days of the end of the adviser's fiscal year
File (not deliver) a brochure amendment outside the annual cyclePromptly, whenever information in the brochure becomes materially inaccurate
A firm with a December 31 fiscal year end has to file its annual updating amendment by around March 31, but it has until around April 30 to actually get the updated brochure, or the summary of changes, into clients' hands. Treating both deadlines as the same date is a common mistake in explainers that only cite the filing side.

Where to find a firm's Form ADV Part 2A

Form ADV is not an EDGAR filing. Advisers file it electronically through the Investment Adviser Registration Depository (IARD), and the SEC publishes the resulting data, including current brochures, through Investment Adviser Public Disclosure (IAPD) rather than EDGAR's full-text search. That is a common point of confusion for anyone used to looking up 10-Ks or 8-Ks on EDGAR: an adviser's CRD number, not a CIK, is the identifier to search by.

Working with Form ADV data in code

SecFeed's Form ADV API pulls the same registration data, by CRD number or by name search, as structured JSON:

curl "https://secfeedapi.com/v1/form-adv/firms?crd=104596" \
  -H "Authorization: Bearer YOUR_API_KEY"

A firm lookup returns its registration status, offices and filing history:

{
  "crd": "104596",
  "name": "EXAMPLE CAPITAL MANAGEMENT LLC",
  "secRegistered": true,
  "mainOffice": { "city": "New York", "state": "NY" },
  "filings": [
    { "formType": "ADV", "filingDate": "2026-03-20" }
  ]
}

In Python, with the SecFeed SDK:

from secfeed import Client

sf = Client("YOUR_API_KEY")
firm = sf.form_adv_firms(crd="104596")
print(firm["name"], firm["secRegistered"])

The adviser lookup tutorial walks through both the firm and individual search endpoints end to end, including how to pull the brochure filings themselves rather than only the registration record shown above.

Frequently asked questions

What is Form ADV Part 2A?

It is the narrative "firm brochure" a registered investment adviser must give clients and prospective clients, written in plain English rather than check-the-box fields. It covers the firm's services, fees, conflicts of interest and disciplinary history across 18 required items.

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

Part 1A is structured data filed electronically, mainly for regulators, covering facts like assets under management and disciplinary history in check-the-box fields. Part 2A is the narrative brochure written for clients, covering the same general topics in prose rather than structured fields, plus items like fees, brokerage practices and proxy voting that Part 1A does not disclose.

Does every investment adviser have to file a Part 2A brochure?

Only advisers registered with the SEC are required to prepare and deliver a Part 2A brochure. Exempt reporting advisers, who file a limited version of Form ADV because they qualify for an exemption from full registration, generally do not have to prepare Part 2A.

When is the Form ADV annual update due?

The annual updating amendment, covering both Part 1A and Part 2A, must be filed with the SEC through IARD within 90 days of the end of the adviser's fiscal year. Delivering the updated brochure, or a summary of its material changes, to clients is a separate requirement due within 120 days of fiscal year end.

Where can I find a firm's current Form ADV Part 2A brochure?

Current brochures are published on Investment Adviser Public Disclosure (IAPD), searchable by firm name or CRD number, not on EDGAR. SecFeed's Form ADV API returns the same registration and filing data by CRD for use in code.

Get this data as clean JSON

SecFeed turns SEC filings into structured data with one API call: GET /v1/form-adv/firms. Free key, no card needed.

Get a free API key →

For information only, not investment advice. Data from public SEC filings; verify important figures on SEC.gov. See our AI Disclosure.