The State of the ADV Brochure 2026
What 16,424 current Form ADV Part 2A brochures disclose, read topic by topic. Where the gaps are, what the SEC is looking at now, and what to expect before the 2027 amendment season.
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Luna research
The State of the ADV Brochure
2026
- 01Ten findings
- 02The dataset: what was read, and how
- 03The core, the long tail, and the gaps
- 04Size, business model, and the smallest SEC advisers
- 05Length, templates, and amendment season
- 06What this SEC is looking at
- 07What Luna expects before March 31, 2027
- 08Appendix: all 48 topics by peer segment
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- 16,424
- current brochures, from 94.7% of SEC-registered advisers
- 48
- disclosure topics; 99.3% of addressed readings tied to their source passage
- 1 in 4
- brochures appear to leave out a topic most comparable firms address
Ten findings
The headline results, aggregate only. The report gives the method, the peer groups and all 48 topics.
- 01
99%+
The basics are near-universal.
Fee schedule, code of ethics, personal trading, strategies and risk of loss, and the custody statement are each addressed by 99% or more of comparable advisers.
- 02
73%
The gaps are in the economics, not the basics.
Among advisers without private funds, 73% address revenue sharing or cash sweep conflicts (a topic read with lower accuracy) and 78% custodian economic benefits: the subjects of the June 2026 risk alert.
- 03
1 in 4
One brochure in four appears to leave out something most peers address.
Under a strict test, 4,082 brochures carry at least one point to consider. The most common: trade allocation, cybersecurity risk and trade aggregation.
- 04
69%
AI is described mostly as a risk, rarely as a service.
About one adviser in five (vendor templates counted once) addresses AI tools. Of the brochures that do, 69% name a specific risk in the text around the cited passage, and 5% mention AI in Item 4, which describes the service.
- 05
66% vs 27%
Cybersecurity is a story of two industries.
66% of advisers serving pooled vehicles describe cybersecurity risk; 27% of advisers serving individuals do.
- 06
83% vs 95%
Among advisers without private funds, the smallest have the thinnest fee disclosure.
Under $100 million without private funds, 83% explain how fees are calculated, against 95% at $100 million to $500 million.
- 07
53%
“We do not” is half of disclosure.
Of advisers that address performance fees, with vendor templates counted once, 53% say the firm charges none. Silence and a clear no read very differently.
- 08
21%
Operational topics are the quietest.
Trade error policy 21%, trades between client accounts 29%, best execution review 46%.
- 09
22 pages
Longer is fuller, up to a point.
The shortest fifth of brochures addresses 68% of the topics that apply to it; past about thirty pages, extra length adds explanation, not coverage.
- 10
56%
Amendment season is one month.
9,228 of the 16,424 current brochures were filed in March 2026. It will repeat in March 2027.
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Data as of the SEC’s public Form ADV files, September 30, 2026. Luna reads brochures; it does not decide whether any brochure meets any rule. A topic most peers cover is common practice, not a requirement. Nothing here is legal advice, and no finding concerns a named firm. The report may be quoted with attribution.