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Form ADV Part 1A Item 2A(9) · Answer type: yn · Item 2 - SEC Registration
Item 2A(9) asks whether the firm is a newly formed adviser relying on rule 203A-2(c) because it expects to be eligible for SEC registration within 120 days.
This registration path provides a temporary window for startup advisory firms that anticipate meeting standard SEC registration requirements but have not yet reached those thresholds. The firm must have a reasonable expectation of qualifying under another Item 2A category within 120 days of initial registration.
Common scenarios include new firms with committed capital that will push AUM above the large adviser threshold of $100 million, or firms that expect to begin advising registered investment companies or other institutional clients that trigger SEC registration requirements.
The 120-day window reflects the time typically needed for new advisory firms to onboard initial clients, deploy capital, and establish operational scale. Without this rule, new firms might face regulatory gaps during their startup phases.
This is a transitional status that should evolve into permanent registration basis as the firm grows. Firms cannot remain indefinitely on the newly formed adviser pathway without demonstrating progress toward other registration qualifications.
Yes
The firm reports that it is a newly formed adviser expecting SEC eligibility within 120 days under Item 2A(9).
No
The firm does not claim newly formed adviser status - it qualifies under current AUM or client thresholds in other Item 2A categories.
2A(9) - Are a newly formed adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days (Yes / No).
This appears in Item 2, SEC Registration, which explains the firm's basis for SEC registration eligibility.
Newly formed adviser status indicates a startup firm in transition toward permanent SEC registration basis. This can signal both opportunity and risk for potential clients considering early relationships with emerging advisory firms.
The 120-day expectation suggests the firm has business plans and client commitments that should lead to qualification under standard registration categories. However, startup projections may not materialize as expected.
The status does not guarantee that the firm will successfully transition to permanent registration basis within the projected timeframe. Market conditions, client acquisition challenges, or operational issues may delay growth plans.
The answer also does not reveal specific business plans, target AUM levels, or client acquisition strategies. Newly formed advisers may pursue different growth paths depending on their intended market focus.
Use 2A(9) as a signal to evaluate the firm's business maturity and growth trajectory. This matters for clients who prefer established firms versus those willing to work with emerging advisers.
Yes
The firm reports newly formed adviser status under Item 2A(9). On Best Investors, check the ADV filing date to understand how recently the firm was established and whether subsequent amendments show progression toward other registration categories.
Review regulatory AUM in Item 5F(2)(c) to see current asset levels and assess progress toward standard thresholds. Compare this with later filings to track the firm's growth trajectory.
Look at services in Item 5G and client types in Item 5D to understand the firm's intended business model and target market that should drive qualification for permanent registration status.
Check employee count in Item 5B for organizational scale that supports the firm's growth expectations and operational capacity.
No
The firm does not claim newly formed adviser status. Check other Item 2A boxes for current registration basis. Established firms typically qualify under large adviser thresholds or specialized categories like investment company adviser status.