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ADV Brochure Review

Your brochure, read against the firms most like yours.

Luna reads your current Form ADV Part 2A against 48 disclosure topics and compares it with brochures from advisers of your size and business model, drawn from 16,424 current brochures. Where most of your peers cover a topic and you do not, it says so, with the evidence. You decide what to change.

Included in every paid plan: Solo, Firm and Firm Plus

Example rows from a review
Billing in advance or arrears“Management fees are billed quarterly in advance.”
Covered96% of peers
Soft dollar benefits“We do not receive soft dollar benefits.”
Says it does not apply
Trade aggregationPoint to consider: most comparable firms say whether they combine client orders.
Not found84% of peers

Example rows. The wording is illustrative, not any firm's brochure.

Advisers Act Rule 204-1; Form ADV General Instructions

An adviser amends its Form ADV, including the Part 2A brochure, at least once a year, within 90 days of the end of its fiscal year, and promptly when information in the brochure becomes materially inaccurate. For most firms that means a March deadline and a brochure rewritten against last year's version, without knowing what comparable firms say.

What it does

All 48 topics, read for you

Fees and billing, conflicts, brokerage and trading, custody, risks, discipline and more. For each one: covered, says it does not apply, or not found, with the line from your brochure that shows it.

Compared with your real peers

Advisers of your size band, with or without private funds, from every current SEC brochure. A vendor template shared by many firms counts once, so one template cannot set the norm.

Points to consider, with the evidence

A topic becomes a point to consider only when most comparable firms address it under two different peer definitions, and the reading is confident. Each point quotes the passage it rests on, or notes the absence.

Checked before you see it

Every point is checked against your actual brochure before the review is delivered, so a topic you cover under an unusual heading is not raised as missing.

Suggested wording for each point

For every point to consider: the facts to confirm first, then starting-point wording for your brochure, written for your firm from your own brochure and Form ADV. Placeholders mark what only you know. Nothing is copied from another firm's brochure.

Your policies, checked against your brochure

Send your compliance manual and Luna shows where it describes a practice your brochure does not mention, where your brochure describes something your policies do not address, and where the two say different things. Your manual stays confidential.

Topics that do not apply to you

Where your Form ADV Part 1 shows a topic cannot arise at your firm, for example no private funds or no custody, the review says so and why, instead of raising it.

Delivered within one business day

Ask for your review and it is prepared from your brochure on file with the SEC and delivered to your Luna workspace, as a report you can read in Luna or download in Word for your amendment work.

Not a customer?

The ADV Pass is $795 for one review cycle, with suggested wording and the policies check, delivered by email as a PDF and a Word file, and credited in full if you take an annual plan within 90 days.

Start free. Every price is on the pricing page.