Over the past two decades, Form ADV Part 1 has undergone major changes driven by crises, regulations, and the SEC’s push for transparency. What started as a simple compliance form now offers allocators a structured, regulator-sourced lens into the real-time state of an adviser’s business.
Key Milestones of Form ADV Part 1
- 2000: SEC mandates electronic filing via IARD and enhances Item 11 for clearer disciplinary disclosures.
- 2011: Post Dodd-Frank, new reporting on private funds via Section 7.B.(1) adds fund-level insights.
- 2017: Major overhaul brings:
- Item 5.K: Separately managed account (SMA) details.
- Schedule R: Umbrella registration for related advisers.
- Item 1.I: Disclosure of social media channels used for advisory business.
- 2021: The new Marketing Rule introduces Item 5.L, disclosing whether performance marketing, testimonials, or endorsements are used.
Takeaway: ADV Part 1 isn’t static. It reflects the SEC’s evolving expectations - and offers allocators a window into how managers are responding to market, operational, and compliance pressures.