Best Investors
Sign in
Best Investors
Sign in
Form ADV Part 1A Item 2A(10) · Answer type: yn · Item 2 - SEC Registration
Item 2A(10) asks whether the firm is a multi-state adviser that is required to register in 15 or more states and relies on rule 203A-2(d) for SEC registration eligibility.
This registration path is for firms that would otherwise face a complex web of state registrations. Instead of registering with 15 or more individual state securities authorities, the firm can register with the SEC under this rule. The 15-state threshold reflects the regulatory burden of maintaining multiple state registrations.
The key word is "required" - the firm must actually need to register in those states based on client location, business activities, or state rules. A firm cannot simply choose to register in 15 states to trigger SEC eligibility.
This path often applies to firms with clients spread across many states but regulatory AUM below the standard large adviser threshold of $100 million in Item 2A(1). The firm might serve high-net-worth individuals in multiple states or provide specialized services that require broad state coverage.
Do not confuse 2A(10) with other multi-state rules or simple business presence. This specific checkbox requires actual registration requirements in 15 or more states, not just clients or marketing in multiple locations.
Yes
The firm reports that it qualifies as a multi-state adviser under rule 203A-2(d) and Item 2A(10).
No
The firm does not claim this registration basis - it may qualify under a different Item 2A path or register only with fewer states.
2A(10) - Are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d) (Yes / No).
This appears in Item 2, SEC Registration, which explains the firm's basis for SEC registration eligibility.
Multi-state adviser status reflects a geographically dispersed business model. These firms often serve clients across broad regions or provide specialized services that attract clients from multiple states. The SEC registration path simplifies compliance by replacing many state registrations with federal oversight.
This status can signal operational sophistication. Managing compliance across 15+ states requires systems and expertise that smaller, local firms may lack. However, it does not guarantee investment quality or superior client service.
The answer does not reveal which specific states the firm serves or the distribution of its client base. A firm might have most clients in a few states but still trigger multi-state requirements through specific business activities.
The threshold also does not indicate firm size beyond the multi-state requirement. Some multi-state advisers have substantial AUM that would qualify for large adviser status under 2A(1). Others remain below $100 million AUM but qualify through geographic spread.
Use 2A(10) to understand the firm's compliance framework and geographic reach. This can matter for clients who value experience with multi-state regulations or who may relocate frequently.
Yes
The firm reports multi-state adviser status under Item 2A(10). On Best Investors, check total regulatory AUM in Item 5F(2)(c) to see whether the firm also meets size thresholds for other registration paths.
Review client information in Item 5C to understand the firm's geographic client distribution. A Yes on 2A(10) should align with a business model that serves clients across multiple states.
Look at services in Item 5G to understand what the firm offers. Multi-state advisers often provide specialized services like financial planning, investment management, or institutional consulting that attract clients regardless of location.
No
The firm does not claim multi-state adviser status on this line. Check other Item 2A boxes to see the actual registration basis. The firm might qualify as a large adviser under 2A(1), a mid-sized adviser under 2A(2), or use another specialized category.
Some firms serve multiple states but do not trigger the 15-state registration requirement due to state exemptions or limited business activities in each location.