Form ADV Part 2A
Form ADV Part 2A is the investment adviser's narrative brochure: a plain-English document describing the firm's advisory business, fees, conflicts of interest, and disciplinary history. It is filed through IARD and delivered to clients, and it is the part of Form ADV that clients and examiners actually read.
- Who handles it
- Registered investment advisers, as the client-facing narrative portion of Form ADV.
- Filed through
- IARD
- Applies to
- SEC-registered RIA, State-registered RIA, Dually registered
What the form asks for
- Advisory business and assets under management
- Fees and compensation
- Performance-based fees and side-by-side management
- Types of clients
- Methods of analysis, investment strategies, and risk of loss
- Disciplinary information
- Other financial industry activities and affiliations
- Code of ethics, participation in client transactions, and personal trading
- Brokerage practices
- Review of accounts
- Client referrals and other compensation
- Custody
- Investment discretion and voting client securities
- Financial information
The work behind the filing
Keep the fee schedule in the brochure equal to the fee schedule you bill
The brochure states how the firm charges. The billing system is what the firm actually charges. When those drift, the brochure is inaccurate and the exam finding writes itself. Caddi can reconcile the billing configuration against the disclosed schedule on a schedule and flag divergence when it appears rather than at year end.
Evidence delivery per client
The obligation is not to publish the brochure, it is to deliver it and be able to prove delivery client by client. That proof usually lives across the CRM, the email system, and the document store. Caddi can drive the send and write the evidence back to each client record as it happens.
Generate the real change set
A summary of material changes should be produced from a genuine comparison against the last delivered version, not written from recollection. Caddi can maintain the versioned comparison so the summary is evidence-backed.
Questions
What is Form ADV Part 2A?
Form ADV Part 2A is the investment adviser's plain-English narrative brochure. It describes the advisory business, fees, conflicts of interest, investment strategies, and disciplinary history, and it is delivered to clients.
What is the difference between Form ADV Part 2A and Part 2B?
Part 2A is the firm brochure describing the advisory business as a whole. Part 2B is the brochure supplement covering the individual supervised persons who provide advice to a specific client.
Is Form ADV Part 2A the same as the brochure?
Yes. Part 2A is what the rules and most compliance teams refer to as the firm brochure.
How do I evidence that the Part 2A brochure was delivered?
Delivery evidence is a books-and-records problem, not a filing problem. It usually means proving, per client, that the current version went out and when. That record is typically spread across your CRM, your email system, and your document store, which is why firms reconstruct it under exam pressure instead of maintaining it. Caddi can assemble and maintain that evidence continuously across those systems.
Does Caddi file this form for me?
No. Caddi does not submit filings to IARD, FINRA Gateway, EDGAR, or any regulator, and it is not a substitute for your compliance program or your CCO. Caddi automates the work around the filing: gathering the underlying data out of your portfolio, CRM, and document systems, reconciling it against the prior filing, flagging what changed, and evidencing delivery. A human still reviews and files.
Related forms
The filing is the easy part
Caddi does not file forms. It runs the work around them: pulling the underlying data out of your portfolio, CRM, and document systems, reconciling it against the prior filing, and evidencing delivery. See it run on your own stack.
See the compliance specialistThis page describes what the form is and the work it creates. For requirements, deadlines, and whether any of it applies to your firm, see SEC — Form ADV Part 2 instructions.