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Form ADV Part 1A Item 5F(2)(e) · Answer type: number · Item 5F - Regulatory Assets Under Management
Item 5F(2)(e) is the number of non-discretionary accounts included in the firm's regulatory AUM reporting. This counts individual accounts where the adviser provides ongoing supervision but clients retain approval authority over individual trades.
This account count pairs with 5F(2)(b) non-discretionary RAUM dollars to show both the scale and distribution of the firm's non-discretionary business. Some firms concentrate non-discretionary assets in few accounts, while others spread them across many relationships.
Non-discretionary accounts are those where clients want ongoing professional advice but prefer to approve individual investment decisions before execution. The adviser monitors portfolios, makes recommendations, and provides continuous oversight, but waits for client authorization before trading.
The non-discretionary account count combines with 5F(2)(d) discretionary accounts to reach 5F(2)(f) total accounts in the Item 5F table. These are account-level counts - one client might maintain both discretionary and non-discretionary accounts with the same firm.
Account counts represent regulatory AUM relationships only, excluding planning-only clients, project-based consulting, or other advisory arrangements that do not qualify for continuous portfolio supervision under 5F(1).
Some firms serve primarily non-discretionary clients who prefer control over trading decisions. Others focus mainly on discretionary relationships, showing minimal counts in 5F(2)(e). Many firms offer both models to accommodate different client preferences.
5F(2)(e) - Non-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 non-discretionary management as of its Form ADV reporting date.
The non-discretionary account count helps you understand how the firm distributes assets among clients who retain trade approval authority. Combined with non-discretionary dollar amounts, it provides insight into typical account sizes and the firm's experience serving clients with approval-based relationships.
If you prefer retaining control over individual investment decisions, look for firms with meaningful non-discretionary account counts and ask about their client communication processes for trade recommendations and approvals.
A large non-discretionary count does not indicate superior service, investment skill, or client outcomes. Some firms excel with approval-based relationships while others work better with discretionary authority. The count also does not show response times, client satisfaction with the approval process, or implementation efficiency.
The figure does not represent total client relationships, since clients may hold multiple accounts or share accounts with family members. It also excludes planning-only or consulting relationships that do not involve continuous portfolio supervision.
Zero or blank 5F(2)(e) when other Item 5F fields show data typically means the firm operates primarily or exclusively with discretionary trading authority.
The value is a whole number representing the count of non-discretionary accounts as of the Form ADV reporting date. For example, 35 means 35 non-discretionary accounts.
On the firm's Best Investors ADV panel, find Item 5F and look for the non-discretionary accounts row labeled 5F(2)(e). Compare this to 5F(2)(d) discretionary account count to see how the firm splits its business by trading authority.
For rough average account size context, divide 5F(2)(b) non-discretionary RAUM by the 5F(2)(e) account count when both figures are present. This provides only a filing-date snapshot and actual account sizes vary significantly.
If 5F(2)(e) is much larger than 5F(2)(d), the firm primarily serves clients who prefer approval-based relationships. If both counts are substantial, the firm accommodates different client preferences for trading authority.
When evaluating firms, ask about their non-discretionary service model, typical response times for client approvals, minimum account requirements, and whether they allow clients to switch between discretionary and non-discretionary arrangements.