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Item 5C provides a headcount view of the investment adviser's client base during its most recently completed fiscal year. It reports approximate client totals and the percentage of clients who are non-United States persons, giving you insight into the firm's scale and international scope.
This section complements the dollar-focused view in Item 5F regulatory AUM with relationship counts. The sections measure different populations. Item 5C can include clients without RAUM, and one client can have multiple RAUM accounts.
Item 5C(1) asks for the approximate number of clients who received investment advisory services during the firm's last fiscal year. The SEC provides response categories ranging from "1-10" up to "More than 5,000" with a follow-up question for firms with more than 100 clients to provide a rounded count.
Item 5C(2) requests the approximate percentage of those clients who are non-United States persons. This figure helps gauge the firm's international client focus and cross-border compliance considerations.
The client counts include all advisory relationships, not just asset management accounts. A client receiving financial planning services without ongoing portfolio management would still count in 5C(1) even if they do not appear in the RAUM figures from Item 5F.
On Best Investors, Item 5C typically appears as a compact section within the ADV form panel, often showing the client range category and non-U.S. percentage when applicable.
Find Item 5C on the firm's ADV form panel on Best Investors. The section shows the firm's reported client count range and international client percentage.
Review 5C(1) - approximate client count to understand the firm's relationship scale. Categories progress from small boutiques ("1-10" or "11-25" clients) through mid-sized practices ("101-250" or "251-500" clients) to large enterprises ("More than 5,000" clients). When the firm selects "More than 100," look for the rounded follow-up number.
Do not divide 5F(2)(c) total regulatory AUM by the 5C(1) client count. The result mixes managed-account assets with a broader advisory-client count and does not show a typical account or client.
Check 5C(2) - non-U.S. persons percentage for the reported share of clients who are non-U.S. persons. The percentage does not establish cross-border expertise or the services those clients receive.
Consider the client count beside the firm's reported services in Item 5G Advisory Services. These fields show reported scale and service types, but they do not establish service depth, efficiency, or customization.
Compare client metrics across multiple firms you are evaluating. Similar-sized firms might serve very different client segments, affecting service levels, minimum account sizes, and cultural fit for your situation.
Item 5C provides approximate figures from the firm's most recent fiscal year end, not current client counts. The numbers may not reflect recent client additions, departures, or relationship changes since the filing date.
The client count does not distinguish between service levels or relationship types. One client might receive comprehensive wealth management services, while another gets limited consulting or planning work. All count equally in 5C(1) regardless of service scope or fee levels.
RAUM divided by the Item 5C client count is not a valid average account-size calculation because the fields cover different populations.
Item 5C does not indicate account minimums, typical account ranges, or client acceptance criteria. Some firms with high average account sizes might still accept smaller clients in specific circumstances. Others might have rigid minimums above their reported averages.
The section does not address client retention, satisfaction, or turnover rates. A firm might report high client counts while experiencing significant churn, or it might maintain stable long-term relationships with slower growth.
The non-U.S. persons percentage in 5C(2) covers legal status, not geographic location. U.S. citizens living abroad count as U.S. persons, while foreign nationals residing in the U.S. count as non-U.S. persons. The percentage does not directly indicate where clients live or do business.
Finally, Item 5C does not reveal the firm's capacity for new clients or its growth plans. A firm operating at capacity might have different service availability than one actively seeking new relationships.