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Form ADV Part 1A Item 5F(2)(d) · Answer type: number · Item 5F - Regulatory Assets Under Management
Item 5F(2)(d) is the number of discretionary accounts included in the firm's regulatory AUM reporting. This counts individual accounts where the adviser has discretionary trading authority, not the dollar value of those accounts.
This account count pairs with 5F(2)(a) discretionary RAUM dollars to show both the scale and distribution of the firm's discretionary business. A firm might have high discretionary assets concentrated in few accounts, or spread across many smaller accounts.
Discretionary accounts are those where clients have granted the adviser authority to make investment decisions and execute trades without getting approval for each transaction. The count includes only accounts that qualify as regulatory AUM under the firm's 5F(1) continuous and regular supervision reporting.
The discretionary account count combines with 5F(2)(e) non-discretionary accounts to reach 5F(2)(f) total accounts in the Item 5F table. These are account-level counts, not client counts - one client might have multiple accounts.
Account counts do not distinguish between individual accounts, joint accounts, entity accounts, or trust accounts. They also do not indicate account minimums, average balances, or client demographics beyond the discretionary vs non-discretionary authority split.
Some firms operate primarily with discretionary authority, showing most of their account count in 5F(2)(d). Others mix discretionary and non-discretionary services, splitting accounts between the two categories based on client preferences.
5F(2)(d) - Discretionary total number of accounts (number).
This is one field in Item 5F, "Regulatory Assets Under Management." The firm reports the count of accounts under discretionary management as of its Form ADV reporting date.
The discretionary account count helps you understand how the firm's discretionary assets are distributed. Combined with discretionary dollar amounts, it provides insight into average account sizes and the firm's client base structure.
If you prefer working with firms that have experience managing accounts similar to your size, compare your expected account value to the rough average discretionary account size (dividing 5F(2)(a) dollars by 5F(2)(d) count). However, remember this is only a filing-date snapshot and actual account sizes vary widely.
A large account count does not indicate service quality, investment performance, or client satisfaction. Some firms excel with many smaller accounts while others focus on fewer larger relationships. The count also does not show client retention, account growth rates, or service delivery methods.
The figure does not represent the total number of people the firm serves, since clients may have multiple accounts or share accounts with spouses or family members. It also excludes non-RAUM relationships like planning-only clients or advisory arrangements that do not qualify for regulatory AUM reporting.
The value is a whole number representing the count of discretionary accounts as of the Form ADV reporting date. For example, 85 means 85 discretionary accounts.
On the firm's Best Investors ADV panel, find Item 5F and look for the discretionary accounts row labeled 5F(2)(d). Compare this to 5F(2)(e) non-discretionary account count to see how the firm splits its account base by trading authority.
For rough average account size context, divide 5F(2)(a) discretionary RAUM by the 5F(2)(d) account count. Remember this is a filing-date calculation only and actual account sizes vary significantly above and below any average.
If 5F(2)(d) is much larger than 5F(2)(e), the firm primarily serves clients who prefer discretionary trading authority. If both counts are substantial, the firm accommodates both client preferences.
When evaluating firms, ask about account minimums for discretionary services, typical account size ranges, and how they handle clients who want to start small and grow their accounts over time.