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Form ADV Part 1A Item 10A · Answer type: yn · Item 10 - Control Persons
Item 10A asks whether any person not named in Item 1.A. or Schedules A, B, or C directly or indirectly controls the firm's management or policies.
Form ADV names control persons in Item 1.A. and Schedules A, B, and C. Item 10A asks about a person who controls the firm but is not named in those places.
Control means the power to direct or cause the direction of management and policies, whether through voting agreements, contractual arrangements, family relationships, or economic power. This is not about passive ownership stakes or routine business relationships. The SEC looks for situations where someone can effectively run the firm or dictate major decisions without appearing in the formal ownership structure.
For example, control can arise through a voting agreement or management contract rather than a simple ownership percentage.
Yes
The firm reports that a person not named in the listed Item 1 or Schedule sections controls its management or policies.
No
The firm reports No and does not report an additional control person under Item 10A. This answer does not independently prove that the filing lists every person who could exercise control.
10A - Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies?
This checkbox sits in Item 10, "Control Persons." Firms must answer Yes or No.
A Yes answer reports a control person who is not named in the sections listed by the question. The checkbox does not describe how that control affects client service, investment decisions, or daily operations.
A Yes means the named ownership schedules do not contain every control person reported by the firm. The checkbox does not identify the additional person, explain the source of control, or state how that control affects clients.
A Yes does not establish that the arrangement is improper. A No does not independently verify that the filing is complete.
Yes
Check Item 10 and Schedules A, B, and C for the person's identity and the reported relationship. If those entries do not explain the arrangement, request the control-person details from the firm.
No
Review Item 1.A. and Schedules A, B, and C for the control persons the firm does report. Treat the No as the firm's answer to Item 10A, not as independent proof that no other control exists.