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Item 6A identifies non-advisory business activities that the investment adviser itself conducts alongside its advisory services. It covers financial services like broker-dealer operations, insurance sales, banking, accounting, and law practice - activities that might create conflicts of interest or additional revenue streams beyond pure advisory work.
This section focuses on what the adviser entity does directly, not what affiliated companies do. Related-person activities appear in Item 7A Financial Industry Affiliations. Item 6A reveals potential conflicts within the adviser's own operations.
Each checkbox represents a different business line that might influence advisory recommendations. An adviser operating as a broker-dealer (6A(1)) can earn commissions on securities transactions. An adviser selling insurance (6A(6)) might recommend insurance products for additional compensation. An adviser operating as a bank (6A(7)) could promote banking services to advisory clients.
Items 6A(1) through 6A(14) cover common dual-registration scenarios: broker-dealer, registered representative, commodity advisor, real estate, insurance, banking, trust services, municipal advisory, accounting, law practice, and other financial sales activities.
Understanding Item 6A helps you identify potential conflicts and evaluate whether the adviser's recommendations might be influenced by non-advisory revenue opportunities. Some investors prefer "fee-only" advisers who avoid these additional business activities entirely.
On Best Investors, Item 6A appears as a checklist within the ADV form panel, typically showing Yes answers for active business lines alongside the primary investment advisory services.
Open the firm's ADV form on Best Investors and locate Item 6A. Scan for Yes answers, which indicate non-advisory business activities that might affect your relationship.
Pay particular attention to 6A(1) - broker-dealer and 6A(2) - registered representative, which enable securities sales for commissions. These dual registrations create potential conflicts between advisory recommendations and transaction-based compensation.
If either 6A(1) or 6A(2) is Yes, ask the firm how it manages conflicts between advisory and brokerage activities. Some firms maintain strict separation between advisory and brokerage recommendations. Others integrate both services but require clear disclosure when commission opportunities exist.
Look for 6A(6) - insurance broker or agent if insurance plays a role in your financial plan. Insurance sales can provide valuable client services but also create incentives to recommend higher-commission products over potentially better alternatives.
Check 6A(7) - bank and 6A(8) - trust company for additional fiduciary services that might benefit your situation. Banking and trust operations can offer integrated wealth management but may also create pressure to keep assets within the adviser's institutional framework.
Note 6A(12) - accountant and 6A(13) - lawyer for professional service combinations that might streamline your financial and legal planning. These arrangements can provide efficiency and coordination but might limit your access to independent professional advice.
Review 6A(14) - other financial product sales for non-standard activities that require further investigation. The firm should specify these activities in follow-up text when 6A(14) is marked Yes.
Cross-reference Item 6A with Item 7A affiliations to understand the full scope of potential conflicts, including both direct activities and related-person relationships.
Compare Item 6A patterns across multiple advisers you evaluate. Firms with many Yes answers operate more complex, potentially conflict-laden businesses. Firms with few or no Yes answers focus more purely on advisory services with fewer conflict management challenges.
Item 6A identifies business activities but does not quantify their revenue importance or frequency of client impact. A Yes on insurance sales might represent occasional transactions or a major revenue source - the checkbox format does not distinguish.
The section does not describe conflict management procedures or separation policies that might mitigate potential problems. Some dual-registered firms maintain strict protocols to manage conflicts, while others provide minimal separation between business lines.
Item 6A does not indicate whether additional business activities are available to all clients or limited to specific situations. Some firms offer brokerage services only when requested, while others actively promote commission-based products.
The section also does not address fee structures or pricing for non-advisory services. Dual-registered firms might offer competitive pricing on additional services or use advisory relationships to cross-sell higher-margin products.
Quality and competitiveness of non-advisory services remain unclear from Item 6A checkboxes. A firm might excel at investment advisory work while providing mediocre insurance or accounting services, or vice versa.
Finally, Item 6A reflects current business registrations but does not indicate future plans or strategic direction. Firms might be expanding into new business lines or exiting existing activities without immediate Form ADV updates.