| name | form-adv |
| language | en |
| description | Drafts SEC- or state-filed Form ADV Parts 1A/1B/2A/2B for investment adviser registration, producing IARD-ready responses, brochures, and supplements. Use when drafting or amending Form ADV, preparing RIA registration, building Part 2A brochures or Part 2B supplements, or compiling IARD filings. Trigger: "Form ADV", "RIA registration", "investment adviser brochure", "Part 1A", "Part 1B", "Part 2A", "Part 2B", "IARD", "SEC filing", "state registration". |
Form ADV Parts 1 and 2
Produces a complete, internally consistent Form ADV (Parts 1A/1B/2A/2B) ready for compliance review and filing.
Prerequisites
Gather before drafting:
- Entity formation docs and ownership cap table
- AUM calculations (discretionary / non-discretionary)
- Advisory agreements, fee schedules, billing policies
- Compliance manual, code of ethics, custody and proxy voting policies
- Affiliations and related-person disclosures
- Disciplinary history for firm and management persons
- Advisory services list and client types
- Supervised person bios (Part 2B)
- Prior filings or amendments (if any)
- Target jurisdiction(s) and state-specific requirements
Deliverables
- Part 1A responses (IARD-ready)
- Part 1B (if state-registered)
- Part 2A brochure (plain-English, client-facing)
- Part 2B supplements (per supervised person)
- Cover page with filing date
- Open Issues list for missing or unverified data
Workflow
1. Intake — Populate Data Table
| Data Point | Notes |
|---|
| Legal name / DBAs | Match formation docs |
| CRD / SEC file number | If existing registration |
| Principal office / mailing | Consistent across all parts |
| CCO name / contact | Confirm authority |
| Ownership 25%+ | Supports Schedules A/B |
| RAUM (disc / non-disc) | Current SEC instructions |
| Client types / counts | Match agreements |
| Services offered | Match marketing materials |
| Fees / billing | Match agreements |
| Affiliations | Related persons list |
| Custody status | Flag direct fee deduction |
| Disciplinary events | Never infer absence — verify |
2. Draft Part 1A
- Identifying info, organization form, fiscal year
- Owners, control persons, org chart
- Advisory services and business activities
- RAUM calculations and methodology
- Client types and counts
- Private fund reporting (if applicable)
- Custody, safeguards, account authority
- Financial industry affiliations and related persons
- Soft dollars, brokerage, principal/agency cross trades
- DRPs if any event applies
- Schedules A/B/C as required
3. Draft Part 1B (State-Registered Only)
- State-specific questions per jurisdiction
- Bonding, net worth, or custody statements if required
- Additional state-regulator disclosures
4. Draft Part 2A Brochure
Required items (Items 1–18):
Cover Page → Material Changes → Table of Contents → Advisory Business → Fees and Compensation → Performance-Based Fees → Types of Clients → Methods of Analysis / Strategies / Risk of Loss → Disciplinary Information → Other Financial Industry Activities → Code of Ethics / Personal Trading → Brokerage Practices → Review of Accounts → Client Referrals and Other Compensation → Custody → Investment Discretion → Voting Client Securities → Financial Information
Content requirements:
- Plain-English narrative, consistent terminology
- Conflicts disclosed with mitigation measures
- Fee examples with tiers and billing timing
- Strategy-specific risk disclosures
- Custody and safeguarding explanation
- Solicitor/referral arrangements
- Proxy voting policy availability
5. Draft Part 2B Supplements
Per supervised person:
- Name, title, business address
- Education and business experience (last 5 years)
- Professional designations and issuing bodies
- Disciplinary events
- Other business activities and additional compensation
- Supervision structure and contact info
6. Cross-Part Consistency Checks
7. Open Issues
- Tag unresolved items as
[TBD — source needed, due: DATE]
- Tag regulatory ambiguity as
[VERIFY] for counsel review
Pitfalls
- Disciplinary history: Never state "no disciplinary history" without verified sources.
- Legal conclusions: Report facts and required disclosures only — avoid legal opinions.
- Outdated instructions: Always use current SEC Form ADV instructions and state guidance.
- Legalese in Part 2A: Keep brochure client-facing and plain-English.
- Inconsistent figures: Cross-check all numbers and dates across every part and schedule.
- Unclear thresholds: If state requirements or thresholds are ambiguous, flag
[VERIFY] and request confirmation.
Key changes from the original:
- Frontmatter: Removed
tags (not in spec). Tightened description — third-person, clear trigger list, under 1024 chars.
- Removed redundant sections: Merged "Output Structure / Process" into a clear Deliverables section and a sequential Workflow with numbered steps.
- Part 2A structure: Replaced verbose code-fenced template with a compact inline flow (
→ chain) — same 18 items, ~60% fewer tokens.
- Guidelines → Pitfalls: Renamed and reformatted as scannable bold-key entries per best practices.
- Consistency checks: Converted to a checklist (
- [ ]) for trackable use during drafting.
- Line count: Reduced from 137 lines to 119 lines while preserving all domain-accurate content.
