Form ADV Parts 1, 2A, 2B and 3 (Form CRS), Explained

Form ADV is not one form with a few checkboxes. It is five separate documents, each written for a different audience and some running on different update schedules: Part 1A and 1B are the structured registration data regulators and the public search, Part 2A and 2B are the plain-English brochures a firm gives clients, and Part 3 is Form CRS, a short relationship summary retail clients get before they ever sign anything. This guide walks through what each part actually contains and clears up the deadlines that get collapsed into one number when they are not.

Five documents, not one

Our Form ADV Part 1 guide and Form ADV Part 2A guide cover those two parts in depth. This guide fills in Part 2B and Part 3, and puts every part's deadlines next to each other.

Part 1: what regulators and the public see

Part 1A is a structured, check-the-box filing covering the adviser's ownership, business practices, assets under management and disciplinary history, required of every adviser. Part 1B adds a handful of items required only from advisers registered with a state rather than the SEC. Both are filed electronically through IARD and are the half of Form ADV published, as structured data, on Investment Adviser Public Disclosure. Because it is structured, this is the only part of Form ADV a tool can search by CRD number or firm name without parsing prose.

Part 2A and 2B: the brochures

Part 2A is the "firm brochure," a narrative, plain-English document covering the adviser's services, fee schedule, conflicts of interest and disciplinary history, required of advisers registered with the SEC. Part 2B is a separate, shorter document about a specific person rather than the firm: the supervised individuals who actually give the advice and have direct contact with a client, or who have discretionary authority over a client's account. Where Part 2A describes the business, Part 2B describes each covered individual's formal education, business background for roughly the last five years, and any disciplinary history relevant to a client deciding whether to trust that person's advice. If a person has no relevant education or no business experience in the period Part 2B covers, the brochure supplement has to say so rather than leave it blank.

Under Rule 204-3, the brochure rule, a registered adviser must deliver the current Part 2A brochure, along with the Part 2B supplement for anyone advising that specific client, before or at the point the client signs an advisory agreement, and must offer the current versions to existing clients at least once a year.

Part 3: Form CRS

Form CRS, formally Part 3 of Form ADV, is a relationship summary written for retail investors rather than for regulators or institutional clients. It came out of the SEC's rulemaking package that also created Regulation Best Interest, with a compliance date of June 30, 2020, and it applies to SEC-registered advisers that serve retail investors, alongside broker-dealers, who file an equivalent summary. The point of Form CRS is brevity and plain language: it is meant to be short enough that a retail investor will actually read it, covering the relationships and services offered, fees and costs, conflicts of interest, and the adviser's disciplinary history, in a standardized format that makes two firms' summaries easier to compare side by side than two full brochures would be.

Form CRS runs on its own update clock, separate from Part 2's annual cycle: a firm must amend its Form CRS within 30 days of any information in it becoming materially inaccurate, not just once a year. Like Part 1, it is filed through IARD, and firms with a public website must also post their current Form CRS there.

The deadlines side by side

Collapsing these into "Form ADV is updated annually" misses that Part 3 and Part 2B each carry their own off-cycle trigger, and that the trigger for Part 3 is a flat 30 days, not tied to the fiscal year at all.

Looking up an adviser's current filings

Because Part 1 is the structured half of Form ADV, it is also the part you can query directly rather than read as a document. SecFeed's Form ADV API returns the current Part 1A and 1B data, by CRD number, straight from the SEC's Form ADV data file:

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

from secfeed import Client

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

The response covers the registration and AUM fields Part 1A discloses; the brochures themselves, Part 2A, 2B and Form CRS, are documents rather than structured records, so they are read as filed rather than queried field by field.

Frequently asked questions

How many parts does Form ADV have?

Five in practice: Part 1A, Part 1B, Part 2A, Part 2B and Part 3 (Form CRS). People often shorthand this as "two parts" (Part 1 and Part 2) or "three parts" (adding Form CRS), which is not wrong exactly, but it hides that 2A and 2B are separate documents about different things, the firm versus the individual.

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

Part 2A is the firm brochure: it describes the advisory business as a whole, its fees and its conflicts of interest. Part 2B is the brochure supplement: it describes a specific supervised person who actually advises a client, including that person's education, business background and relevant disciplinary history.

Does every adviser have to file Form CRS?

Only SEC-registered advisers that offer services to retail investors have to file Form CRS. An adviser that serves only institutional clients is generally not required to prepare one.

How often does Form CRS need to be updated?

Within 30 days of any information in it becoming materially inaccurate, separate from the annual updating amendment that applies to the rest of Form ADV. It is also updated alongside that annual amendment even without a specific trigger.

Can I search Form ADV Part 2B the way I can search Part 1?

Not through Investment Adviser Public Disclosure's structured search. Part 1 is the structured, searchable half of Form ADV; Part 2B is a document delivered to clients, and while it is kept on file, it is not indexed as searchable fields the way Part 1A's registration data is.