RIA Form ADV Explained: What Every Investment Adviser Needs to Know in 2025
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Understand each part of Form ADV, filing timelines, and how to stay compliant with SEC and state regulators
If you are a registered investment adviser (RIA) or plan to become one, understanding and properly filing your Form ADV is essential. It is the cornerstone of your regulatory obligations with the SEC and state securities authorities and defines how your firm communicates with both regulators and clients.
At LawVisory, we help advisers draft, file, and maintain Form ADV filings that are fully compliant and tailored to their business models. In this guide, we walk through each section, highlight what’s required in 2025, and explain the most common mistakes to avoid so your firm remains compliant, confident, and exam-ready.
What Is Form ADV?
Form ADV is the primary disclosure document that all RIAs — whether SEC or with individual states — must file through the Investment Adviser Registration Depository (IARD). It is made up of four distinct parts and is publicly accessible via the SEC’s website.
Breakdown of Form ADV Parts
ADV Part 1: Firm Disclosure Form
Part 1 provides regulators with factual and operational information about your firm. It is filed online through IARD and must be updated annually, or sooner if there are material changes.
This section includes:
- Ownership and organizational structure
- Number of employees and office locations
- Types of advisory services offered
- Regulatory Assets Under Management (AUM)
- Custody status
- Disciplinary history for both the firm and its personnel
- Affiliations with broker-dealers or other financial entities
- Control persons and indirect owners
- Other business activities
Regulators use this section to understand your business model and identify potential risks before an examination. Accuracy is key—especially regarding AUM, employees, and custody details.
ADV Part 2A: Firm Brochure
Part 2A, also known as the Firm Brochure, describes your services, fees, investment philosophy, and conflicts of interest in plain, client-friendly language. It must be uploaded to IARD, delivered to clients, and updated every year or whenever there are material changes.
- Firm overview and background
- Advisory services and fee structure
- Methods of analysis and investment strategies
- Disciplinary disclosures (if any)
- Conflicts of interest and how they are mitigated
- Code of ethics and brokerage practices
- Review process for accounts
- Financial conditions that may affect your ability to meet obligations
Because this is your most client-facing document, it should be written clearly, professionally, and consistently with your marketing materials. For state-registered advisers, make sure to also include Item 19 – Requirements for State-Registered Advisers.
ADV Part 2B: Brochure Supplements
Part 2B, or the Brochure Supplement, focuses on the individuals who actually provide investment advice to clients. It is not filed with regulators but must be delivered to clients and updated whenever there are personnel changes or relevant disciplinary events.
Each supplement must include:
- The adviser’s education and business experience
- Any disciplinary history
- Other outside business activities
- Compensation arrangements and potential conflicts of interest
- The supervision structure in place
Every Investment Adviser Representative (IAR) must have their own Part 2B. Firms should maintain records confirming that clients received the correct supplement before or at the time of signing an advisory agreement, as required by Rule 204-3.
ADV Part 3: Form CRS (Client Relationship Summary)
Part 3, known as Form CRS (Client Relationship Summary), applies to SEC-registered advisers that serve retail investors. It provides a concise, client-friendly summary of key facts about the firm’s services, fees, and relationships, written in plain language and limited to two pages. Form CRS must be filed through IARD as a text-searchable PDF and delivered to retail investors before or at the time the advisory relationship is established, and again whenever any material change occurs.
Form CRS should not exceed two pages and must be filed through IARD and delivered to retail clients.
It includes:
- The types of services your firm provides
- Fees and costs associated with those services
- Conflicts of interest
- Legal obligations and standards of conduct
- How clients can file complaints or request additional information
The SEC expects firms to use straightforward, conversational wording such as “We do,” “We don’t,” and “You should ask us.” The CRS must also be submitted as a text-searchable PDF through IARD.
ADV Filing Deadlines
Filing Requirement | Deadline |
Initial Registration | Before launching advisory services |
Annual Amendment | Within 90 days of the firm’s fiscal year-end (typically by March 31) |
Material Updates | Promptly, generally within 30 days of the change |
Delivery to Clients (Parts 2A 7 2B) | Within 120 days of fiscal year-end or upon request |
CRS Delivery | At account opening and whenever updates are made |
Common ADV Filing Mistakes to Avoid
Even well-managed firms can make avoidable errors when preparing their Form ADV. The most common include:
- Using generic or templated language in Part 2A that doesn’t accurately reflect your services
- Failing to update your ADV after changes in fees, AUM, or personnel
- Indicating “no custody” when you in fact have it through fee deductions or standing letters of authorization
- Forgetting state-specific disclosure requirements
- Not maintaining delivery logs for brochures and supplements
Each of these mistakes can raise regulatory red flags or create unnecessary compliance risk. Taking the time to review your filings carefully, or working with experienced counsel, helps you avoid these pitfalls.
How LawVisory Helps
LawVisory provides comprehensive Form ADV support for firms of all sizes. Our services may include:
- Drafting and customization of Parts 1, 2A, 2B, and CRS
- Developing SEC or state registration strategies and onboarding through IARD
- Aligning disclosures with your compliance manual, website, and marketing materials
- Preparing annual amendments and tracking material changes
- Managing communications with regulators and supporting you during exams
- Conducting attorney-client privileged reviews of all policies and updates
We deliver complete, compliant filings in as little as five to seven business days, offering both flat-fee and retainer-based options to fit your firm’s needs.
Frequently Asked Questions
Exempt Reporting Advisers must file only a limited Form ADV Part 1A through the IARD. They are not required to prepare or deliver Form ADV Parts 2 or 3 (Form CRS). ERA filings are informational only and must be updated annually.
No. Form CRS applies only to SEC-registered investment advisers that serve retail investors—natural persons who receive advice primarily for personal, family, or household purposes. If your firm works exclusively with institutional or high-net-worth entities, you are not required to file or deliver Form CRS.
Advisers with $100 million or more in Regulatory Assets Under Management (RAUM) are generally required to register with the SEC. Firms managing less than $100 million typically register at the state level, unless they qualify for a specific exemption (for example, as an ERA or under multi-state registration relief).
Yes. You must deliver updated copies of Form ADV Parts 2A and 2B to all clients within 120 days of your fiscal year-end, or promptly whenever there are material changes. Delivery may be electronic if the client has consented to receive documents that way.
Failure to file your annual amendment or to update your Form ADV after material changes may result in late fees, administrative penalties, or even withdrawal of your registration. The SEC and state regulators enforce timely filing under Rule 204-1(b) of the Advisers Act.
Need Help with Your Form ADV?
Whether you are registering for the first time, preparing for an audit, or simply want to make sure your filings are accurate, LawVisory provides precise, attorney-led Form ADV compliance support.
📅 Book Your Confidential ADV Review Call
📧 info@lawvisory.com | 🌐 www.lawvisory.com
This material is provided for informational purposes only and does not constitute legal advice. For specific questions about compliance with Form ADV or SEC/state requirements, please consult legal counsel.



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Jeffrey Smith
Jeffrey Smith, JD. is the Managing Attorney at LawVisory, specializing in SEC compliance, privacy regulation, and regulatory risk management for RIAs, broker-dealers, and fintech innovators. With over a decade of experience advising regulated entities, Jeff helps firms operationalize compliance through actionable frameworks and evidence-based readiness programs.
December 2, 2025
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