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Info / Form ADV / 6A(1)

6A(1) Broker-dealer (registered or unregistered)

Form ADV Part 1A field explainer

Form ADV Part 1A Item 6A(1) · Answer type: yn · Item 6 - Other Business Activities

What this means

Item 6A(1) asks whether the investment advisory firm itself is actively engaged as a broker-dealer, registered or unregistered. It reports a business activity of the adviser entity, not an affiliate.

A broker-dealer can buy and sell securities for customers or for its own account. The checkbox does not state what compensation the adviser receives, whether advisory clients use its brokerage services, or how often the activity occurs.

The broker-dealer activity can be relevant when advisory clients also use the firm's brokerage services. Item 6A(1) does not report whether they do.

A firm marks Yes when it reports the broker-dealer activity named by this checkbox.

Yes

The firm reports that it is engaged as a broker-dealer. Item 6A(1) does not report registration details, compensation, client use, or conflict controls.

No

The firm reports No and does not report broker-dealer activity for the adviser entity under 6A(1). It can still report broker-dealer affiliates in 7A(1) or registered representatives in 6A(2).

Official Form ADV question

6A(1) - Broker-dealer (registered or unregistered) (Yes / No).

This checkbox is part of Item 6A, which covers other business activities that the investment adviser engages in beyond providing investment advice.

Why it matters

A Yes identifies the additional business activity. Review compensation and Item 8 transaction answers to determine whether the activity affects advisory clients.

A Yes does not tell you how the firm manages conflicts between their advisory and brokerage functions, what percentage of their revenue comes from each business line, how they price their brokerage services versus their advisory services, or whether they consistently prioritize their advisory duties.

If 6A(1) is Yes, review Item 5E for reported compensation methods, Item 8 for transaction and brokerage answers, and the firm's available disclosures for actual client-facing arrangements.

How to read a firm's answer

Yes

The firm reports operating as both an adviser and broker-dealer. On the firm's Best Investors ADV panel, review Item 8 for reported client transaction practices, 5E for compensation methods, and Item 11 for any separately reported disclosure events.

Check 8A(1) for principal transactions and 8B(1) for agency cross transactions. Request the brokerage commission schedule and compare it with the fees in the advisory agreement.

No

The firm reports No under 6A(1). Check Item 7A(1) for reported broker-dealer affiliates and 6A(2) for registered representatives. Read those answers separately.

Review Item 8C for the brokerage authority the firm reports.

Related questions

Sources

  • Form ADV Part 1A, Item 6A (Other Business Activities)
  • Firm ADV form on Best Investors (Item 6A activities section)