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Form ADV Part 1A Item 5C(2) · Answer type: number · Item 5 - Clients
Item 5C(2) asks approximately what percentage of the firm's clients are non-United States persons.
This measures the international component of the client base by counting non-U.S. clients as a percentage of total clients served during the most recent fiscal year. A non-United States person typically includes foreign individuals, non-U.S. corporations, and other entities organized or domiciled outside the United States.
The percentage reflects client count distribution, not asset distribution. A firm might have 20% non-U.S. clients by count but 50% non-U.S. assets by value if international clients tend to have larger accounts. Conversely, many smaller international clients could represent a high client percentage but modest asset percentage.
International clients may create additional regulatory complexities for advisory firms including cross-border compliance, tax reporting requirements, currency considerations, and coordination with foreign regulatory authorities.
This figure comes from the same fiscal year client count reported in Item 5C(1) and provides geographic context for understanding the firm's market reach and operational complexity.
5C(2) - Approximately what percentage of your clients are non-United States persons.
This appears in Item 5C, Advisory Clients, alongside the total client count to provide geographic distribution context.
Non-U.S. client percentage indicates the firm's international scope and experience serving clients across different regulatory environments, tax systems, and market conditions. Higher percentages suggest global expertise and operational capabilities.
International client relationships often require specialized knowledge of foreign tax regulations, currency hedging, international investment opportunities, and cross-border compliance requirements. Firms with significant non-U.S. client bases typically develop these capabilities.
However, international client percentage does not guarantee superior global investment expertise or better international market access. Some firms serve non-U.S. clients with the same strategies and services offered domestically.
The percentage also does not reveal which specific countries or regions the non-U.S. clients represent. A firm might concentrate on particular geographic areas or serve clients distributed globally.
Compare this figure with regulatory AUM breakdowns in Item 5F when available to understand whether non-U.S. clients contribute proportionally to total assets or represent different average account sizes.
Look for the percentage in Item 5C(2) on the firm's Best Investors ADV panel. Zero or blank typically means the firm reports no significant non-U.S. client presence, indicating primarily domestic operations.
Higher percentages suggest more international client relationships and potentially more complex operational requirements for currency, tax, and regulatory compliance across multiple jurisdictions.
Calculate the approximate number of non-U.S. clients by applying this percentage to the total client count from Item 5C(1) to understand the scale of international operations.
Consider how this client geographic distribution aligns with services offered in Item 5G and any specialized international capabilities the firm might advertise.
Review foreign principal office status in Item 2A(4) to see whether non-U.S. clients correlate with foreign-based operations or represent international expansion from a U.S. base.