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Form ADV Part 2A

Brochure Benchmark

How advisers like yours describe common topics in their brochures. Luna read the current Part 2A brochure of 16,424 SEC-registered advisers (October 2026). Pick the profile closest to your firm. Free, no account.

Then see your own brochure the same way. Luna’s ADV Brochure Review reads your brochure topic by topic, compares it with these peers, and shows what is worth a second look before your annual amendment.

Private funds

5,533 comparable advisers

TopicItemPeers that address it
Code of ethics described and offered11
100%
Other fees clients pay5
100%
Investment strategies8
100%
Risk of loss statement8
99%
Custody15
99%
Billing timing and method5
99%
Personal trading11
99%
Performance-based fees6
99%
Broker selection factors12
99%
Methods of analysis8
99%
Fee schedule5
99%
Broker-dealer registration or affiliation10
97%
Trading in the same securities as clients11
97%
Compensation for client referrals14
97%
Economic benefits from non-clients14
97%
Fee deduction15
97%
Compensation from sales of securities5
96%
Trade aggregation12
96%
Insurance affiliation10
96%
Other adviser and fund affiliations10
96%
Research and other benefits12
95%
Fees negotiable5
95%
Fee calculation basis5
95%
Promoter arrangements14
94%
Qualified custodian statements15
94%
Refund of prepaid fees5
93%
Side-by-side management6
93%
Recommending related services10
93%
Directed brokerage12
92%
Soft dollar benefits12
91%
Custodian platform benefits12
85%
Allocation of trades12
85%
Revenue sharing and cash sweep5
73%
Brokerage for client referrals12
68%
Compensation for selecting other advisers10
67%
Futures registrations10
64%
Options, margin and leverage risks8
55%
Concentration risk8
42%
Principal and agency cross transactions11
42%
Best execution review12
41%
Standing letters of authorization15
40%
Cybersecurity risk8
22%
Cross trades between client accounts11
16%
Trade errors12
15%
Use of AI or algorithmic tools8
9%
Digital asset risks8
7%

In Luna

Your brochure, compared with firms like yours

The benchmark shows what your peers cover. The ADV Brochure Review shows how your own brochure compares, topic by topic, with the evidence from your own words.

All 48 topics, read for you

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

Compared with your real peers

Advisers of your size, with or without private funds, from every current SEC brochure. Shared vendor templates count once.

Points to consider, checked

Where most comparable firms cover a topic and yours does not, Luna raises it as a point to consider. Each one is checked against your actual brochure before you see it.

Suggested wording, and your policies

Each point comes with the facts to confirm and starting-point wording written for your firm. Send your compliance manual and Luna also shows where it and your brochure do not line up. In Word, ready for your amendment.

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
  1. Step 1Start with your CRD

    Luna works from your current brochure on file with the SEC. Nothing to upload.

  2. Step 2Luna reads and compares

    Every topic, against advisers like yours, with a reviewer check on each point raised.

  3. Step 3In Luna within one business day

    Your review is prepared and checked, then delivered to your Luna workspace. Read it in Luna or in Word; what to change is always your call.

Included in every paid Luna plan, from Solo at $199 a month. Start a trial, then ask for your review at info@lunacompliance.io from your work email. Not a Luna customer? The ADV Pass is $795 for one review cycle, delivered within one business day and credited in full if you take an annual plan within 90 days (terms). Part of Luna, the compliance platform for SEC-registered advisers: marketing review, code of ethics and personal trading, policies, the compliance calendar and exam preparation in one place. The review describes what peers commonly cover; it is not legal advice and does not decide whether your brochure meets any rule.

How this is counted

  • Peers are SEC-registered advisers with or without private funds, in the same band of regulatory assets, from their Form ADV Part 1A.
  • Addresses it means the brochure describes the practice or says the firm does not do it. Only firms the topic applies to are counted.
  • Shared templates count once. Firms using the same vendor wording count as one voice.
  • Small groups are not shown. A figure based on fewer than 20 peers is left out.
  • The full findings, with the regulatory context, are in The State of the ADV Brochure 2026.
  • A topic many peers cover is common practice, not a requirement. This page is not legal advice and makes no finding about any firm.