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Form ADV Part 1A Item 2A(1) · Answer type: yn · Item 2 - SEC Registration
Item 2A(1) asks whether the firm qualifies as a large advisory firm under SEC registration thresholds.
This checkbox covers firms that either: (a) have regulatory assets under management of $100 million or more, or (b) are already SEC-registered submitting an annual update and have $90 million or more in regulatory AUM. The two-part test reflects different entry and maintenance thresholds for SEC registration.
Most advisory firms that register with the SEC (rather than only with states) mark Yes on this line. The $100 million threshold is the standard dividing line between state-only registration and SEC registration eligibility. The $90 million maintenance threshold prevents firms from bouncing between SEC and state registration due to minor AUM fluctuations.
Regulatory AUM comes from Item 5F on the same Form ADV. This includes both discretionary and non-discretionary client accounts that count toward the firm's registration eligibility.
Do not confuse 2A(1) with other Item 2A registration bases like 2A(2) mid-sized firms or 2A(5) investment company advisers. Each checkbox represents a different path to SEC registration eligibility.
Yes
The firm marks this box when it meets the large-adviser size path - generally $100 million or more in regulatory AUM to enter SEC registration, or $90 million or more to remain SEC-registered on an annual update. The checkbox is a registration-basis claim, not a quality rating.
No
The firm reports No and does not claim this registration basis under 2A(1). Review the other Item 2 answers for the basis it does report.
2A(1) - Are a large advisory firm that either: (a) has regulatory assets under management of $100 million (in U.S. dollars) or more, or (b) is SEC-registered and is submitting an annual updating amendment and has regulatory assets under management of $90 million (in U.S. dollars) or more (Yes / No).
This appears in Item 2, SEC Registration, which explains the firm's basis for SEC registration eligibility.
This line reports a claimed basis for SEC registration. It identifies a regulatory AUM threshold, not the firm's operating resources, compliance quality, or service range.
However, SEC registration status does not indicate superior investment skill, better client service, or lower fees. Many excellent advisers operate below SEC thresholds and register only with states. SEC registration reflects size, not quality.
The threshold also does not reveal specific AUM figures beyond the minimum. A firm marking Yes might have exactly $100 million or several billion in AUM. Check Item 5F regulatory AUM for the actual amount.
Use 2A(1) to understand the firm's regulatory environment and scale category. Pair it with AUM figures and service descriptions to get a complete picture of the firm's advisory business.
Yes
The firm reports large advisory firm status under Item 2A(1). On Best Investors, confirm this against total regulatory AUM in Item 5F(2)(c) to verify the firm meets the dollar thresholds. AUM should be at or above $100 million for new registrations, or $90 million for continuing registrations.
Check whether other Item 2A boxes are also marked Yes. Some firms qualify under multiple registration bases - for example, large AUM plus investment company adviser status.
Review Item 5G services for the services the firm separately reports.
No
The firm does not claim large advisory firm status on this line. Look at other Item 2A and 2B checkboxes to see the actual registration basis. The firm might qualify as a mid-sized adviser under 2A(2), an investment company adviser under 2A(5), or use another specialized registration category.
If all Item 2A boxes are No, check Item 2B for exemption categories like venture capital or private fund advisers.