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Form ADV Part 1A Item 5F(3) · Answer type: currency · Item 5F - Regulatory Assets Under Management
Item 5F(3) asks for the approximate amount of total regulatory assets under management that is attributable to clients who are non-United States persons. This represents a subset of 5F(2)(c) total RAUM, not a separate or additional asset total.
Non-United States persons typically include foreign nationals, non-resident aliens, foreign corporations, foreign partnerships, and foreign government entities. The specific definition depends on tax, securities, and regulatory contexts, but generally covers clients who do not qualify as "U.S. persons" under relevant regulations.
This figure helps regulators and potential clients understand the international scope of the firm's client base and regulatory AUM. Some advisers serve primarily domestic clients with minimal non-U.S. person assets, while others specialize in international clientele or global markets.
5F(3) represents only the portion of regulatory AUM attributed to non-U.S. person clients, not the total value of international investments or foreign securities held in portfolios. A firm serving only U.S. persons might still invest client assets globally, but would report zero or minimal amounts in 5F(3).
The calculation requires firms to categorize their regulatory AUM clients as U.S. persons or non-U.S. persons and attribute the associated asset values accordingly. This can involve complex determinations for certain client types, joint accounts, or entities with mixed ownership structures.
Some firms with substantial non-U.S. person clientele might report 5F(3) figures approaching their total RAUM, while others focusing on domestic markets typically show much smaller non-U.S. attributions or zero amounts.
5F(3) - Approximate amount of total regulatory assets under management (reported in Item 5.F.(2)(c)) attributable to clients who are non-United States persons (currency).
This is one field in Item 5F, "Regulatory Assets Under Management." The firm reports non-U.S. person attributable assets as of its Form ADV reporting date.
5F(3) reveals whether the firm serves meaningful non-U.S. person clientele or focuses primarily on domestic relationships. If you are a non-U.S. person seeking advisory services, firms with substantial 5F(3) amounts may have more experience with international client needs, tax considerations, and cross-border regulatory requirements.
If you are a U.S. person, the 5F(3) figure provides context about the firm's client base diversity but does not directly affect your potential advisory relationship. Some investors prefer firms with international experience for global investment perspectives, while others prioritize firms focused on domestic markets.
A large 5F(3) does not indicate investment performance, service quality, or regulatory compliance. Some firms excel with international clientele while others work better with domestic-only relationships. The figure also does not show the geographic distribution of non-U.S. clients or their specific nationality compositions.
The amount does not represent international investments in client portfolios. A firm serving only U.S. persons might invest extensively in foreign securities, international funds, or global strategies while reporting zero in 5F(3). Conversely, a firm with high non-U.S. person attribution might invest those assets primarily in U.S. securities.
The value is a dollar amount representing the portion of regulatory AUM attributed to non-U.S. person clients as of the Form ADV reporting date. For example, 15000000 represents $15,000,000 in non-U.S. person attributable RAUM.
On the firm's Best Investors ADV panel, find Item 5F and look for 5F(3) if present. Compare this figure to 5F(2)(c) total RAUM to understand the proportion of assets attributed to non-U.S. person clients.
If 5F(3) is much smaller than total RAUM, the firm primarily serves U.S. person clients with limited non-U.S. person attribution. If 5F(3) approaches the total RAUM figure, the firm's client base consists substantially of non-U.S. persons.
Missing or blank 5F(3) when other Item 5F fields show data often means the firm either has minimal non-U.S. person attribution or did not report this optional breakdown on its Form ADV filing.
When evaluating firms as a non-U.S. person, ask about their experience with international clients, familiarity with relevant tax treaties, reporting requirements for your jurisdiction, and any restrictions on services for non-U.S. persons.