Form ADV Disclosure Completeness Scorecard
Form ADV is the document an SEC examiner reads first. It's also where an audit reveals the most quickly: inconsistencies between Part 1A items and Part 2A narrative, missing Part 2B brochure supplements, or a Part 3 (CRS) that doesn't reconcile to actual fee structures. This scorecard reads ADV completeness across all four parts and surfaces the inconsistencies before the examiner does.
What you walk away with
~8 min · 4 categories · 13 items- A completeness index across Form ADV Parts 1A, 2A, 2B, and 3 (CRS).
- A radar chart showing weakest parts.
- A ranked remediation list mapped to the Form ADV Annual Amendment checklist.
- Calibration anchored against IARD validation rules and SEC examination focus areas.
Answer every item (0 of 13 so far) to lock in a banded score and unlock the remediation roadmap. Live category scores update as you go.
Part 1A — Firm characteristics
0 / 4 answeredWhether Part 1A items reconcile to actual firm operations: AUM, business mix, custody, affiliations, disciplinary history.
- Reported AUM reconciles to internal aggregation
Part 1A AUM matches the firm's internal AUM aggregation as of the filing date. Discretionary vs. non-discretionary split is accurate.
- Business mix items match actual revenue and activities
Items 5 (Information About Your Advisory Business) accurately reflect the firm's actual services, account types, and client mix.
- Custody status (Item 9) is accurate and current
Custody disclosures match actual practice. Surprise-exam requirement is met where applicable.
- Disciplinary disclosures are current and complete
Items 11 (Disclosure Information) reflect all required disclosures of the firm and associated persons.
Part 2A — Brochure
0 / 4 answeredWhether the firm brochure is current, plain-English, and reconciles to Part 1A and actual practices.
- Item 5 (Fees and Compensation) reconciles to actual fee schedules
Fee disclosures match the firm's actual fee schedule, advisory agreement, and prior-year billing data.
- Item 6 (Performance-Based Fees) and Marketing Rule alignment
Performance-based fee disclosures and any performance presentation comply with Rule 206(4)-1.
- Item 8 (Methods of Analysis) describes actual investment process
Methods of analysis, investment strategies, and risk-of-loss disclosures match the firm's actual process.
- Item 11 (Code of Ethics) describes the actual code
Code-of-ethics disclosure matches the actual policy, including personal trading restrictions and reporting requirements.
Part 2B — Brochure supplements
0 / 3 answeredWhether brochure supplements exist for every required individual and reconcile to current credentials and disclosures.
- Brochure supplements exist for every required individual
Each individual giving advice to retail clients has a current Part 2B supplement on file.
- Educational background and business experience are current
Each supplement reflects current credentials, professional designations, and business experience.
- Disciplinary and material disclosure events are reflected
Each individual's supplement reflects all required disclosure events with current narrative.
Part 3 — Form CRS
0 / 2 answeredWhether Form CRS is current, accurate, and the firm can prove delivery.
- Form CRS is current and reconciles to Form ADV Parts 1A and 2A
CRS content reconciles to Part 2A disclosures and Part 1A characteristics. No internal inconsistencies.
- Initial and updated CRS delivery is logged per relationship
Every retail relationship has documented CRS delivery (timestamp, channel, recipient) with re-delivery on material change.
Banded score reference
Filing-Risk
0–35%Material inconsistencies between ADV parts or between ADV and actual practice. The annual amendment is exposing unresolved gaps.
Next step: Reconcile Part 1A AUM and business mix to internal data before the next amendment window.
Findings-Possible
35–60%Form ADV is filed but evidence-of-accuracy is uneven. Examination would likely surface inconsistencies.
Next step: Close lowest-scoring part; the remediation list ranks them.
Defensible
60–85%Form ADV reconciles to operations across all four parts. Most exam questions can be answered from the filing alone.
Next step: Tighten Part 2B supplement coverage and CRS delivery proof.
Audit-Ready
85–100%Form ADV is operationalized end-to-end. Filing reconciles to operations; delivery is proven; supplements are current.
Next step: Operate steady-state; re-run before each annual amendment.
Key takeaways
- AUM and business mix reconciliation is the most common Part 1A finding. Internal aggregation discrepancies are immediately visible to examiners.
- Marketing Rule alignment in Part 2A is the highest-leverage Part 2 area in the post-2021 era.
- Part 2B supplement coverage is mechanical to audit. Missing supplements are immediate findings.
- Form CRS delivery proof is increasingly examined. Having the document is necessary; proving delivery is sufficient.
FAQ
How does this differ from the Form ADV Annual Amendment Checklist?
The checklist is exhaustive (every field). This scorecard reads at a higher level — whether each part is internally consistent and reconciles to operations. Use the checklist to close gaps; use the scorecard to know which gaps to close first.
Does this work for state-registered advisers?
Mostly. State-registered advisers file the same ADV but file with state regulators rather than the SEC. The scorecard's structural reads apply; the band calibration is anchored to SEC examination patterns.