How do you read a firm's Form ADV before you join it?
A reading order for the Form ADV of a firm you are thinking of joining: the ownership schedules in Part 1A, then Items 4, 5, 8, 10, 12 and 14 of the Part 2A brochure. What each one asks the firm to disclose, what to read for, and the questions each answer should prompt. Every point is tied to the SEC form.
Filed by Tyler Noe

Read the ownership first, then six items of the brochure. Schedules A and B in Part 1A of the Form ADV show who owns the firm, and Items 4, 5, 8, 10, 12 and 14 of the Part 2A brochure show how it is paid, what it recommends, what it is affiliated with and what it receives from others. Each is written in plain English, and each answer is a prompt for a question to ask before a first meeting.
Most advisors meet a firm through its people and its pitch. The Form ADV is the version the firm has filed with regulators, and it sits one search away. A firm that is registered with the SEC or a state has a public brochure written to a fixed list of items, so the part you want is in the same place in every firm's filing. This guide takes seven of those places in the order that tends to answer the most with the least reading. For what each part of the form is and when it is filed, see what Form ADV is and what each part asks.
1. Schedules A and B: who owns the firm
Schedule A, in Part 1A, lists the firm's direct owners and its executive officers, with each owner's stake shown as a code: NA for under 5%, A for 5% to under 10%, B for 10% to under 25%, C for 25% to under 50%, D for 50% to under 75% and E for 75% or more. It also marks each person as a control person or not. Schedule B goes up the chain. For each owner on Schedule A that is an entity, it lists the owners of 25% or more of that entity, and continues at every level until it reaches a public company. It also lists general partners, trustees and, for an LLC, its elected managers.
Read the two together. A firm that reads as founder-owned on its website can show a holding company at code E on Schedule A and a fund behind it on Schedule B. The longer story of what a sponsor's timeline means for an advisor is in who actually owns the firm you're joining; this is where you find out which structure you are looking at.
2. Item 4: the business and its principal owners
Item 4.A asks the firm to describe itself, including how long it has been in business, and to identify its principal owners. The form's note says the principal owners include the people listed at codes C, D or E on Schedule A. If the name in Item 4.A does not match what you read on Schedule A, that is the first question for the meeting.
Item 4.E is where the firm states what it manages, split between discretionary and non-discretionary assets, with the date it measured them. The date must be within 90 days of the brochure's last update, and the figure may be rounded to the nearest $100,000. The form also lets the firm use a different method here than for the regulatory assets under management it reports in Part 1A. Two numbers that do not match can reflect a different method or a different date, and it is worth asking which one the firm uses when it talks about its size.
3. Item 5: how the firm is paid
Item 5 is the compensation item. It asks for the fee schedule and whether fees are negotiable (5.A), whether fees are deducted from client assets or billed (5.B), what other fees clients pay, such as custodian fees (5.C), and whether fees may be paid in advance and how a refund works (5.D).
The line to find is 5.E. If the firm or any of its supervised persons accepts compensation for selling securities or other investment products, the form requires the firm to say so and to state that this creates a conflict of interest: an incentive to recommend products based on the compensation rather than on a client's needs. It must describe how it addresses the conflict, and say that clients may buy the products elsewhere. If more than half of the firm's advisory-client revenue comes from commissions and similar compensation, the brochure must say that commissions are its primary compensation. A brochure with no 5.E disclosure is telling you that the firm reports no compensation, to itself or its supervised persons, for selling securities or other investment products.
Part 1A asks a narrower question. Its Item 5.E asks how the firm itself is compensated for its advisory services, and one box is commissions. In the SEC's registered-adviser file dated October 2, 2026, 65 of the 1,622 wealth-focused firms checked it, 4.0%. By wealth-focused we mean the SEC-registered advisers with $1 billion or more in regulatory assets, individual or high-net-worth clients, and at least half of their regulatory assets from those clients. Few firms in this group report commissions as a way they are paid for advice.
Source: SEC and FINRA public filings (Form ADV, BrokerCheck, IAPD).
4. Item 8: what the firm recommends, and the risks
Item 8 asks for the methods of analysis and the investment strategies the firm uses, the material risks of each significant one, and, in 8.C, the material risks of any particular type of security the firm recommends primarily. For an advisor, the useful read is for fit with the practice you run. A firm that concentrates on one product type will say so here, along with what can go wrong with it, and that tells you what your clients would be offered and how the firm describes it to them.
5. Item 10: what else the firm is, and who it is related to
Item 10 lists the firm's other financial industry activities and affiliations. It asks whether the firm or any of its management persons is registered, or has an application pending, as a broker-dealer or a representative of one (10.A) or as a futures commission merchant, commodity pool operator, commodity trading advisor or an associated person of one (10.B). Then comes the long list in 10.C: any relationship that is material to the advisory business or to clients with a related person that is a broker-dealer, an investment company or other pooled vehicle, another adviser or financial planner, a futures or commodities firm, a banking or thrift institution, an accountant, a law firm, an insurance company or agency, a pension consultant, a real estate broker, or a sponsor or syndicator of limited partnerships. The firm must identify the related person and, where the relationship creates a material conflict, describe it and say how the firm addresses it.
Item 10.D covers a firm that recommends or selects other advisers for its clients. If the firm receives compensation from them that creates a material conflict, or has other business relationships with them that do, it must describe these, the conflict they create and how it addresses them.
The practical read is to note which of the eleven kinds of related person the firm describes, and which of those sit close to clients' money, such as a bank, an insurance agency or a pooled vehicle.
Part 1A gives a count to set beside Item 10.A. Its Item 5.B(2) asks how many of the firm's employees are registered representatives of a broker-dealer. In the same October 2, 2026 file, 621 of the 1,622 wealth-focused firms reported one or more, 38.3%. That is about four in ten of them. The brochure's Items 5.E and 10.A are where a firm discloses compensation for selling products and the registrations of the firm and its management.
Source: SEC and FINRA public filings (Form ADV, BrokerCheck, IAPD). Counts are of SEC-registered advisers with a US main office, excluding private-residence addresses, with filings through October 1, 2026.
6. Item 12: how it chooses brokers, and what it gets for it
Item 12 is about the broker-dealers the firm uses. The firm describes the factors it considers when selecting or recommending broker-dealers and when judging the reasonableness of their compensation. Within that, three disclosures are required where they apply. Soft dollars (12.A.1) are research and other products or services the firm receives from a broker-dealer or a third party in connection with client transactions, which the firm must describe along with the conflict they create. Client referrals (12.A.2) cover the case where the firm considers whether it or a related person receives client referrals from a broker-dealer or third party when choosing one. Directed brokerage (12.A.3) covers the firm routinely recommending, requesting or requiring that clients use a specified broker-dealer, and the form requires an explanation that the practice may leave the firm unable to achieve the most favorable execution and may cost clients more.
Item 12.B asks whether and when the firm aggregates client orders. If it does not aggregate when it could, the brochure must say what that costs clients. Where the firm names a conflict in these lines, the form asks it to say how the conflict is addressed, and that answer is the one to read twice.
7. Item 14: what the firm receives from others, and pays to others
Item 14 is short and it answers two questions. Under 14.A, if someone who is not a client provides an economic benefit to the firm for providing advice to its clients, the firm must describe the arrangement, explain the conflicts and say how it addresses them. The form counts sales awards and other prizes as economic benefits. Under 14.B, if the firm or a related person directly or indirectly compensates anyone who is not a supervised person for client referrals, the firm must describe the arrangement and the compensation.
An Item 14 that discloses no arrangement means the firm reports no economic benefit from non-clients and no referral payments to outside persons. A long one names the counterparties the firm's economics run through, and each is a question for the meeting.
What to do with the read
Write down, per item, the one sentence you would want the firm to explain in person. The brochure is the firm's own account, so it is a fair basis for a direct conversation, and the ownership and fee answers in particular shape how the practice runs after the move. The other half of the exercise runs the other way: the hiring firm reads your record, and what a new firm checks before it hires you sets that out. The client-facing summary, Form CRS, has its own guide, Form CRS for advisors.
A filing answers what a firm has disclosed, and the move itself raises questions no filing covers. Winthrop & Co. works through those with advisors in confidence, and the advisor never pays: request an introduction.
Sources (5)
- SEC - Form ADV Part 2, Uniform Requirements for the Investment Adviser Brochure and Brochure Supplements (Items 4, 5, 8, 10, 12 and 14)
- SEC - Form ADV Part 1A (Schedule A, Schedule B and Item 5.F)
- SEC - Form ADV General Instructions
- SEC - Investment Adviser Public Disclosure
- SEC - Information About Registered Investment Advisers and Exempt Reporting Advisers (monthly data file)
Frequently asked
How do you read a Form ADV before joining a firm?
What should an advisor look for in a Form ADV Part 2A brochure before joining an RIA?
Filed
October 29, 2026