Financial Requirements for Registration as an Investment Adviser
Updating the Brochure

Timely Updating the Brochure

Part 2A of the Form ADV requires advisers to create narrative brochures containing information about the advisory firm. Both federal and state registered advisers must prepare and deliver a brochure to their clients. They both also have requirements set by the SEC and NASAA for timely updating their brochure

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Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure

Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure

Any RIA compensated under a wrap fee program for sponsoring, organizing, or administering the program, or for selecting, or providing advice to clients regarding the selection of, other investment advisers in the program, does not use the normal brochure or Part 2A of the ADV. Instead, that adviser furnishes clients and prospective clients Part 2A, Appendix 1.

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FINRA’s Change to Rules 5122 and 5123

Brochure Delivery Requirements

Part 2A of the Form ADV requires advisers to create narrative brochures containing information about the advisory firm. Both federal and state registered advisers must prepare and deliver a brochure to their clients according to the brochure delivery requirements set in 17 CFR § 275.204-3 – Delivery of brochures and brochure supplements.

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Part 2A of Form ADV: Firm Brochure

Part 2A of Form ADV: Firm Brochure

Rule 204-3, the brochure rule, is a requirement under the Investment Advisers Act of 1940 that requires investment advisers to provide a written disclosure statement to their clients. The rule applies to all federally registered investment advisers and specifies times during the advisory process at which they must provide the materials. To satisfy this rule, adviser can either provide clients Part 2 of the Form ADV, or they can provide an actual brochure that contains the same information that would be found in Form ADV Part 2A and 2B.

Part 2 of the Form ADV consists of:

  • Form ADV Part 2A: Firm Brochure
  • Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure
  • Form ADV Part 2B: Brochure Supplement describing certain supervised persons.

This blog will cover Part 2A of Form ADV: Firm Brochure, for more information on Form ADV, check out our Form ADV blog now, or our Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure and Part 2A of Form ADV: Firm Brochure blogs being posted soon.

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