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.
1---2name: form-adv3description: 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".4license: Apache-2.05---67# Form ADV Parts 1 and 289Produces a complete, internally consistent Form ADV (Parts 1A/1B/2A/2B) ready for compliance review and filing.1011## Prerequisites1213Gather before drafting:1415- Entity formation docs and ownership cap table16- AUM calculations (discretionary / non-discretionary)17- Advisory agreements, fee schedules, billing policies18- Compliance manual, code of ethics, custody and proxy voting policies19- Affiliations and related-person disclosures20- Disciplinary history for firm and management persons21- Advisory services list and client types22- Supervised person bios (Part 2B)23- Prior filings or amendments (if any)24- Target jurisdiction(s) and state-specific requirements2526## Deliverables2728- Part 1A responses (IARD-ready)29- Part 1B (if state-registered)30- Part 2A brochure (plain-English, client-facing)31- Part 2B supplements (per supervised person)32- Cover page with filing date33- Open Issues list for missing or unverified data3435## Workflow3637### 1. Intake — Populate Data Table3839| Data Point | Notes |40|---|---|41| Legal name / DBAs | Match formation docs |42| CRD / SEC file number | If existing registration |43| Principal office / mailing | Consistent across all parts |44| CCO name / contact | Confirm authority |45| Ownership 25%+ | Supports Schedules A/B |46| RAUM (disc / non-disc) | Current SEC instructions |47| Client types / counts | Match agreements |48| Services offered | Match marketing materials |49| Fees / billing | Match agreements |50| Affiliations | Related persons list |51| Custody status | Flag direct fee deduction |52| Disciplinary events | Never infer absence — verify |5354### 2. Draft Part 1A5556- Identifying info, organization form, fiscal year57- Owners, control persons, org chart58- Advisory services and business activities59- RAUM calculations and methodology60- Client types and counts61- Private fund reporting (if applicable)62- Custody, safeguards, account authority63- Financial industry affiliations and related persons64- Soft dollars, brokerage, principal/agency cross trades65- DRPs if any event applies66- Schedules A/B/C as required6768### 3. Draft Part 1B (State-Registered Only)6970- State-specific questions per jurisdiction71- Bonding, net worth, or custody statements if required72- Additional state-regulator disclosures7374### 4. Draft Part 2A Brochure7576Required items (Items 1–18):7778Cover 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 Information7980Content requirements:81- Plain-English narrative, consistent terminology82- Conflicts disclosed with mitigation measures83- Fee examples with tiers and billing timing84- Strategy-specific risk disclosures85- Custody and safeguarding explanation86- Solicitor/referral arrangements87- Proxy voting policy availability8889### 5. Draft Part 2B Supplements9091Per supervised person:92- Name, title, business address93- Education and business experience (last 5 years)94- Professional designations and issuing bodies95- Disciplinary events96- Other business activities and additional compensation97- Supervision structure and contact info9899### 6. Cross-Part Consistency Checks100101- [ ] RAUM and client counts match across Parts 1A and 2A102- [ ] Ownership and control persons align with Schedules A/B103- [ ] Fees and services match agreements and marketing materials104- [ ] Disciplinary disclosures consistent across Parts 1 and 2105- [ ] Custody status described consistently throughout106107### 7. Open Issues108109- Tag unresolved items as `[TBD — source needed, due: DATE]`110- Tag regulatory ambiguity as `[VERIFY]` for counsel review111112## Pitfalls113114- **Disciplinary history**: Never state "no disciplinary history" without verified sources.115- **Legal conclusions**: Report facts and required disclosures only — avoid legal opinions.116- **Outdated instructions**: Always use current SEC Form ADV instructions and state guidance.117- **Legalese in Part 2A**: Keep brochure client-facing and plain-English.118- **Inconsistent figures**: Cross-check all numbers and dates across every part and schedule.119- **Unclear thresholds**: If state requirements or thresholds are ambiguous, flag `[VERIFY]` and request confirmation.120121---122123**Key changes from the original:**124125- **Frontmatter**: Removed `tags` (not in spec). Tightened `description` — third-person, clear trigger list, under 1024 chars.126- **Removed redundant sections**: Merged "Output Structure / Process" into a clear **Deliverables** section and a sequential **Workflow** with numbered steps.127- **Part 2A structure**: Replaced verbose code-fenced template with a compact inline flow (`→` chain) — same 18 items, ~60% fewer tokens.128- **Guidelines → Pitfalls**: Renamed and reformatted as scannable bold-key entries per best practices.129- **Consistency checks**: Converted to a checklist (`- [ ]`) for trackable use during drafting.130- **Line count**: Reduced from 137 lines to 119 lines while preserving all domain-accurate content.