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.
- Form ADV Part 2A is the narrative "firm brochure" an SEC-registered investment adviser must give clients in plain English, separate from the structured data in Part 1A.
- It has 18 required items, covering fees, conflicts of interest, disciplinary history and how the firm manages money, and every item must be addressed even if it does not apply.
- The annual updating amendment is due to the SEC within 90 days of fiscal year end; delivering the updated brochure or a summary of changes to clients is due within 120 days, a separate deadline.
- Form ADV is filed through IARD and published on Investment Adviser Public Disclosure, not EDGAR, but SecFeed's adviser endpoints return the same data as structured JSON.
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:
| Part | What it is | Who sees it |
|---|---|---|
| Part 1A | Structured, check-the-box data: assets under management, employee count, custody, disciplinary history | Regulators, and the public via Investment Adviser Public Disclosure |
| Part 1B | Additional disclosure pages for state-registered advisers | State regulators |
| Part 2A | The firm brochure: a narrative, plain-English disclosure of the business, fees and conflicts | Clients and prospective clients |
| Part 2B | The brochure supplement, covering individual advisory personnel who work directly with clients | Clients and prospective clients |
| Part 3 | Form CRS, a short relationship summary for retail investors | Retail 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:
| Item | Topic |
|---|---|
| 1 | Cover page: firm name, address, contact information |
| 2 | Material changes since the last annual update |
| 3 | Table of contents |
| 4 | Advisory business: services offered, assets under management |
| 5 | Fees and compensation |
| 6 | Performance-based fees and side-by-side management |
| 7 | Types of clients |
| 8 | Methods of analysis, investment strategies and risk of loss |
| 9 | Disciplinary information |
| 10 | Other financial industry activities and affiliations |
| 11 | Code of ethics, participation in client transactions, personal trading |
| 12 | Brokerage practices |
| 13 | Review of accounts |
| 14 | Client referrals and other compensation |
| 15 | Custody |
| 16 | Investment discretion |
| 17 | Voting client securities (proxy voting) |
| 18 | Financial information |
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.
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:
| Requirement | Deadline |
|---|---|
| File the annual updating amendment with the SEC through IARD | Within 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 client | Within 120 days of the end of the adviser's fiscal year |
| File (not deliver) a brochure amendment outside the annual cycle | Promptly, whenever information in the brochure becomes materially inaccurate |
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.
For information only, not investment advice. Data from public SEC filings; verify important figures on SEC.gov. See our AI Disclosure.