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Form ADV Part 1A Item 2A(8) · Answer type: yn · Item 2 - SEC Registration
Item 2A(8) asks whether the firm is a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with an investment adviser registered with the SEC, and whose principal office and place of business is the same as that registered adviser.
This registration path applies to advisory firms that share ownership and office space with larger SEC-registered advisers. The relationship must involve actual control - not just business partnerships or referral arrangements. One firm must own the other, or both must be owned by the same parent entity.
The shared office requirement is literal. Both firms must operate from the same principal business location, sharing management, systems, and operational infrastructure. This ensures that the related adviser benefits from the regulatory oversight applied to the main SEC-registered firm.
This rule prevents regulatory gaps when large advisory organizations split operations across multiple legal entities but maintain integrated management. Without this provision, some parts of the business might fall below SEC thresholds despite being part of a larger regulated operation.
Do not confuse 2A(8) with simple business affiliations or marketing relationships. The control and office requirements are specific tests that require formal ownership structures and shared physical operations.
Yes
The firm reports that it qualifies as a related adviser under rule 203A-2(b) with the required control and office relationships.
No
The firm does not meet the related adviser criteria - it operates independently or qualifies under different registration paths.
2A(8) - Are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, and your principal office and place of business is the same as the registered adviser (Yes / No).
This appears in Item 2, SEC Registration, which explains the firm's basis for SEC registration eligibility.
Related adviser status typically indicates complex organizational structures within large financial services firms. These arrangements often arise when firms separate different business lines, client types, or regulatory functions while maintaining integrated operations.
The shared control and office requirements suggest operational coordination between the two advisory entities. Clients may benefit from broader resources and expertise available across the related firms, though they contract with the specific adviser filing the Form ADV.
However, related adviser status does not guarantee that clients receive services from both entities or access to the full resources of the parent organization. Each adviser remains separately responsible for its own clients and compliance obligations.
The relationship also does not reveal the specific nature of the control arrangement or how business operations are divided between the related entities. These details may appear in other regulatory filings or client agreements.
Use 2A(8) to understand potential organizational complexity and resource sharing within the advisory structure. This can matter for clients evaluating the firm's stability, resources, and potential conflicts of interest.
Yes
The firm reports related adviser status under Item 2A(8). On Best Investors, look for information about parent companies or affiliated entities in Item 1 and Item 7 that might identify the controlling SEC-registered adviser.
Review regulatory AUM in Item 5F(2)(c) to understand this entity's size relative to what might be expected for a subsidiary or affiliated adviser.
Check services in Item 5G to see whether the firm offers specialized services that complement those of related entities, suggesting operational division of responsibilities.
Look at other business activities in Item 6A and affiliations in Item 7A for additional context about the broader organizational structure.
No
The firm does not claim related adviser status. Check other Item 2A boxes for the actual registration basis. The firm likely operates independently and qualifies through large adviser status or other direct registration paths.
Independent firms may still have business relationships or referral arrangements with other advisers without meeting the specific control and office requirements of this rule.