Form ADV: Full 2025 Guide for Investment Advisors

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Filing Form ADV is a critical part of running a compliant and credible advisory business. This disclosure document provides regulators and clients with a clear picture of your firm’s services, fees, personnel, and potential conflicts of interest.

Along with keeping you compliant, filing Form ADV accurately and on time builds trust with your clients and prospects. So, what information do you need to include in this form? And what does the filing process entail?

Below, we’ll break down everything you need to know about the 2025 Form ADV, including what it covers, who must file, how often to file, and other frequently asked questions. We’ll also highlight how Alden Investment Group can help streamline the filing process from start to finish.

What is Form ADV?

Form ADV is a disclosure document that serves as a central repository for information about investment advisors’ businesses, services, personnel, compensation structures, and potential conflicts of interest.

Regulators use Form ADV to monitor advisors’ compliance and assess their risk. Meanwhile, clients review this form to understand advisors’ services and make informed decisions when selecting a firm.

How is Form ADV Structured?

Form ADV is broken into three parts, and each one serves a distinct purpose. Here’s an overview of Part 1, Part 2, and Part 3:

Part 1: Firm and Personnel Information

Part 1 collects factual data about your advisory firm and its personnel. Regulators use this information to monitor compliance, assess risk, and maintain oversight of the advisory industry.

Part 1 is subdivided into Part 1A and Part 1B:

Part 1A

Part 1A is required for all advisers registering with the SEC or state authorities. It asks you to provide the following information:

Basic firm details, including your firm’s legal name, physical address, business formation, and ownership structure.
Business operations details, including your primary client types (individuals, high-net-worth clients, pension funds, etc.), number of clients, and assets under management (AUM).
Personnel information, where you outline the key members of your firm’s management and advisory staff, along with their roles, qualifications, and professional credentials.
Disciplinary history, including any past legal or regulatory actions involving your firm or its officers.
Financial data based on your firm’s balance sheets, financial stability, and material financial relationships with clients.

Part 1A also includes the following supplemental schedules, which collect additional information about your firm:

Schedule A – Details about direct owners and executive officers.
Schedule B – Information about indirect owners.
Schedule C – Updates on previous paper-filed schedules A and B.
Schedule D – Additional information for Part 1A items that don’t fit in the standard field.
Schedule R – Details about your relationship with any registered advisors you rely on.
Disclosure Reporting Pages (DRPs) – Details about any disciplinary events involving the firm or its affiliated advisers.

Exempt reporting advisers who aren’t registering with a state only need to complete certain Part 1A sections and their related schedules. However, those who register with a state authority must complete all of Form ADV.

Part 1B

Part 1B includes additional questions that only some state securities regulators require. Thus, advisors who register in these states are the only ones who need to complete this section. SEC-only registrants can generally skip it.

In either case, being thorough and transparent throughout Part 1 helps your firm build credibility with regulators and ensures proper compliance.

Part 2: Brochure

Part 2, also known as the “Brochure,” is a narrative document designed primarily for clients and prospects. It communicates your services, fees, investment strategies, disciplinary history, and conflicts of interest in plain English.

Unlike Part 1, which focuses solely on the facts, Part 2 allows you to craft a compelling, client-facing narrative about your firm that highlights your expertise and professionalism. Some key details to address in this section include your:

Services and strategies – Describe your advisory services and explain your approach to risk management.
Fees and compensation – Explain how you charge for your services, whether you use a percentage of AUM, a flat fee, an hourly rate, a performance-based fee, or a combination. Next, disclose any potential conflicts that arise from your proprietary products, affiliate relationships, or referral arrangements.
Disciplinary history – Be transparent about any past actions against your firm. You can use this section to add relevant context to clarify the circumstances surrounding these actions.
Client rights and responsibilities – Outline what clients can expect from your firm and what you require from them to maintain a successful advisory relationship. This is a great place to discuss your data privacy procedures, account access policies, communication frequency, and termination protocols.

As you fill out Part 2, keep your client audience in mind and avoid financial jargon. You can also include examples to simplify complex concepts, such as illustrating how you mitigate any existing conflicts of interest. Most importantly, use this section to build credibility and demonstrate the value your firm provides to clients.

Part 3: Client Relationship Summary

Introduced in 2019, Part 3 is also known as the Client Relationship Summary (Form CRS). This section specifically targets retail investors. It condenses essential information from Parts 1 and 2 into a concise, easy-to-read format, enabling clients to quickly understand your services, fees, and conflicts of interest at a glance.

Here are the topics you’ll want to touch on in this section:

Service offerings – Outline the types of services your firm provides.
Fees and costs – Clearly explain your investment management fees, commissions, and other charges.
Conflicts of interest – Note any potential conflicts in plain language so clients understand how your compensation could influence their recommendations.
Standard of conduct – Clarify whether your firm acts as a fiduciary and how you ensure clients’ best interests.
Conversation starters – The SEC recommends adding prompts to help clients ask meaningful questions during initial consultations, such as:
- “How might your conflicts of interest affect me, and how will you address them?”
- “How do you tailor your investment strategies for clients with goals like mine?”
- “What steps do you take to monitor and manage my portfolio’s risk?”
Visual aids – Part 3 allows you to add visual aids like charts, tables, or infographics, as well as interactive features, such as pop-up definitions, calculators, or short explanatory videos. These visual aids can make complex concepts easier to understand and allow investors to quickly grasp key information about your firm.

Form CRS should only span two pages (or four pages if you’re a dual registrant). Thus, you must keep things concise. Additionally, make sure your information is consistent across all three parts of Form ADV to prevent client confusion and compliance issues.

Who Needs to File Form ADV?

Filing Form ADV is necessary for nearly all investment advisors. If you provide investment advice for compensation, manage client accounts, or publish analyses regarding securities, you’re required to file. Your firm’s size and the clients you serve determine which regulatory body you file with:

Registered Investment Advisers (RIAs) must file Form ADV with the SEC if they manage $110 million or more in AUM. RIAs with less than $110 million typically register with state securities regulators instead.
Exempt Reporting Advisers (ERAs) are firms that qualify for certain exemptions from full SEC registration, such as advising private funds with a limited number of investors. Even though they don’t need full registration, ERAs are still required to file Part 1 of Form ADV with the SEC. This allows the SEC to maintain oversight and monitor the firm’s compliance risks.

Advisers who only provide uncompensated advice, internal research, or guidance exclusively to family clients may not need to file Form ADV. If you think you may qualify for an exemption, consult with a securities attorney or compliance professional to confirm your status.

Frequently Asked Questions (FAQs) About Form ADV

At Alden Investment Group, we work with investment advisors from across the country. As a result, we regularly receive questions about filing Form ADV. Some common ones include:

Q: How often do I need to file Form ADV?

A: All registered advisors must update Form ADV at least once a year, within 90 days of the end of their fiscal year. Even if all of your information remains the same, this filing is required to confirm that your firm’s information is current. Late filings can lead to regulatory scrutiny and reduce clients’ confidence in your firm. Along with this annual filing, you must also update and re-file your Form ADV shortly after any “material changes” occur in your business.

Q: What “material changes” require immediate updates to Form ADV?

A: Not every change at your firm requires an immediate filing. However, certain “material changes” must be reported promptly (within 30 days) to ensure that regulators and clients have accurate, up-to-date information about your business. These include:

Change in firm name
Change in ownership or legal structure
Change in investment advisory programs or custodians
Change in fee schedule
Addition or removal of directors, officers, or advisory personnel
Significant changes to your portfolio strategies

Q: How do I file my Form ADV?

A: After filling out Form ADV, you can file it electronically through the Investment Adviser Registration Depository (IARD), which serves as the central system for both SEC and state-registered advisers. When you file, you’ll need to pay a registration fee, which varies depending on whether you’re registering with the SEC or a state securities authority.

Q: Do I need to file different forms if I operate in multiple states or with multiple client types?

A: No, you don’t need to file separate forms for each state or client type. You submit a single Form ADV that covers your entire advisory business.

Where you file depends on your assets under management. If your firm manages $110 million or more in assets, you must file your Form ADV with the SEC. Smaller firms typically file with their state regulators. Firms registered with both the SEC and one or more states (dual registrants) must comply with the filing requirements for both jurisdictions.

Q: What happens if I make a mistake on my Form ADV?

A: Spelling mistakes or minor formatting issues usually don’t trigger regulatory penalties, but they can affect your credibility with clients. In contrast, significant omissions about your disciplinary history, conflicts of interest, or AUM can result in fines, audits, and enforcement action.

Fortunately, the SEC and state regulators allow you to make amendments to correct errors. Just make sure you submit the revised version promptly and clearly indicate what’s being corrected.

Q: How should I deliver Part 2 and Part 3 to clients?

A: You should deliver Form ADV Part 2 and Part 3 at or before the time of engagement. For existing clients, provide prompt updates anytime material changes occur.

You can share Form ADV with clients in paper or electronic formats. If you choose to send them electronically, just make sure you use a secure delivery method. At Alden Investment Group, our turnkey asset management platform (TAMP)—Alden COVE—offers a secure client portal, simplifying this process for both you and your clients.

Q: How can I simplify the Form ADV filing process?

A: To streamline your Form ADV filings, maintain organized internal records on your AUM, personnel, disciplinary history, and fees. This way, you can access these details quickly when it’s time to file.

Next, invest in compliance software that integrates with Form ADV templates. These solutions can streamline the filing process by automating your calculations, flagging inconsistencies, and guiding you through required schedules.

Finally, always double-check your Form ADV for accuracy and completeness before submitting it.

Simplify Your Form ADV Filings with Alden Investment Group

Filing Form ADV can be time-consuming and complex. Fortunately, you don’t need to navigate it alone. Alden Investment Group can assist with the process, lending you our compliance expertise at every stage.

Along with our comprehensive compliance support, we also offer diverse asset management solutions and cutting-edge technology. By partnering with us, you can enhance your ability to scale, serve clients effectively, and maintain your fiduciary duties with confidence.

Ready to take the stress out of regulatory compliance? Learn how Alden Investment Group can help streamline your Form ADV filings today!

Sources:

SEC. Form ADV (Paper Version).
https://www.sec.gov/files/formadv-instructions.pdf

SEC. Form CRS Relationship Summary; Amendments to Form ADV.
https://www.sec.gov/files/rules/final/2019/34-86032.pdf

SEC. Form ADV, Part 3: Instructions to Form CRS.
https://www.sec.gov/about/forms/formadv-part3.pdf

SEC. Form ADV: Instructions for Part 1A.
https://www.sec.gov/files/rules/final/2016/ia-4509-appendix-b.pdf

SEC. Electronic Filing for Investment Advisers on IARD: IARD Filing Fees.
https://www.sec.gov/investment/electronic-filing-for-investment-advisers-on-iard-iard-filing-fees