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Form ADV Part 1A Item 6A(7) · Answer type: yn · Item 6 - Other Business Activities
Item 6A(7) asks whether the investment advisory firm itself is actively engaged as a bank, including as a separately identifiable department or division of a bank.
The checkbox reports that the adviser entity is engaged as a bank, including a separately identifiable bank department or division. It does not list the banking products offered to advisory clients.
Banking activity can be relevant to compensation, product, or custody questions, but 6A(7) does not prove that the firm recommends bank products or has custody.
A firm marks Yes when it reports the banking activity named by this checkbox.
Yes
The firm reports that it is engaged as a bank or bank department. The answer does not identify services, compensation, custody, or applicable controls.
No
The firm reports No and does not report banking activity for the adviser entity under 6A(7). It can still report a banking affiliate in 7A(8) or use a bank in another role.
6A(7) - Bank (including a separately identifiable department or division of a bank) (Yes / No).
This checkbox is part of Item 6A, which covers other business activities that the investment adviser firm engages in beyond providing pure investment advisory services.
Banking activity identifies another business line that can be relevant if advisory clients use its products or services. Item 6A(7) does not report whether this occurs.
A Yes does not tell you what specific banking services they provide, how their banking and advisory operations are separated, whether they custody client investment assets through their banking function, what their deposit and lending rates are compared to market alternatives, or how they manage conflicts between banking profit motives and advisory obligations.
If 6A(7) is Yes, review Item 9 for reported custody, Item 5E for compensation methods, and 7A(8) for bank affiliations. Ask which reported banking services are available to advisory clients.
Yes
The firm reports operating as a bank. On the firm's Best Investors ADV panel, review Item 9 for reported custody, 7A(8) for banking affiliations, and 5E for compensation methods.
Identify each banking service offered to advisory clients. Compare its account terms and fees with the advisory agreement, and check Item 9 for separately reported custody.
No
The firm reports No under 6A(7). Check 7A(8) for a separately reported bank or thrift affiliate and Item 9 for separately reported custody arrangements.
Look at 5E for the compensation methods the firm reports. A No under 6A(7) does not establish all revenue sources.