The Universe of Form ADV

A comprehensive data analysis of 56,000+ SEC-registered investment advisers β€” their assets, disclosures, institutional holdings, and the firms that shape American finance.

πŸ“… June 2026 πŸ“Š Source: SEC IAPD / Form ADV 🏦 56,107 Firms Analyzed πŸ’° $163 Trillion in AUM

01The Scale of the Industry

Form ADV is the SEC's registration form for investment advisers. Every firm managing money for clients must file one. The result is a remarkable dataset: 56,107 firms, collectively managing $163.2 trillion in reported assets.

56,107
Registered Investment Advisers
37,751 SEC-registered + 18,356 ERAs
$163.2T
Total Regulatory AUM Reported
Across all Form ADV filers
$5.1B
Average AUM per Reporting Firm
Median is far lower β€” heavily skewed
117M
Total Client Accounts Served
Across all registered advisers

Key Insight

Two registration types exist: SEC-Registered Investment Advisers (IAs) β€” firms managing $110M+ in assets and subject to full SEC oversight β€” and Exempt Reporting Advisers (ERAs), typically private fund managers who file a partial Form ADV but are exempt from full registration. ERAs represent nearly one-third (32.7%) of all filers.

Registration Type Breakdown

SEC Reg. IA
37,751
ERA
18,356

Firm Size by Employee Count

Micro <10
16,096
Small 10-99
8,002
Mid 100-999
1,220
Large 1,000+
159

02Where Are the Advisers?

Investment advisory firms cluster around financial hubs. New York and California together account for over 26% of all registered advisers in the country.

New York
8,093 firms
California
6,884 firms
Texas
2,801 firms
Florida
2,471 firms
Massachusetts
1,971 firms
Illinois
1,884 firms
Connecticut
1,621 firms
Pennsylvania
1,451 firms
Colorado
1,203 firms
New Jersey
1,084 firms

The Connecticut Factor

Connecticut's 1,621 advisers punch far above the state's population size β€” driven by the hedge fund capital of Greenwich and Stamford. Similarly, Massachusetts (1,971) reflects Boston's concentration of institutional asset managers like Fidelity, State Street, and Wellington Management.

03The Giants: Top Firms by AUM

A handful of mega-firms dominate the industry. The top 15 firms below collectively manage tens of trillions in assets β€” dwarfing the thousands of boutique advisers.

# Firm Name Total AUM (Reported) State
1The Vanguard Group, Inc.$7.9 TrillionPA
2Fidelity Management & Research Company LLC$3.96 TrillionMA
3Capital Research and Management Company$3.32 TrillionCA
4BlackRock Fund Advisors$3.05 TrillionCA
5Pacific Investment Management Company LLC (PIMCO)$2.62 TrillionCA
6J.P. Morgan Investment Management Inc.$2.55 TrillionNY
7T. Rowe Price Associates, Inc.$1.75 TrillionMD
8Goldman Sachs Asset Management, L.P.$1.66 TrillionNY
9Morgan Stanley Smith Barney LLC$1.40 TrillionNY
10BlackRock Financial Management, Inc.$1.29 TrillionNY
11Wellington Management Company LLP$1.28 TrillionMA
12Merrill Lynch, Pierce, Fenner & Smith Inc.$1.27 TrillionNY
13Charles Schwab Investment Management, Inc.$1.10 TrillionTX
14Geode Capital Management, LLC$1.06 TrillionMA

AUM figures as reported on the firm's most recent Form ADV Part 1 filing. "Regulatory AUM" per Item 5.F may differ from commercially reported AUM figures.

04The Disclosure Landscape

Form ADV Item 11 asks advisers whether they β€” or their personnel β€” have any criminal, regulatory, or civil judicial history. Answering "yes" triggers a Disclosure Reporting Page (DRP). Of the 56,107 firms in the database, 6,519 (11.6%) have at least one affirmative Item 11 disclosure.

548,616
Total Disclosure Records
Across all Item 11 question items
6,519
Firms with Any Disclosure
11.6% of all registered advisers
78,706
11.D(2) Regulatory Events
Most common disclosure type
13,711
Firms with Criminal Disclosures
Item 11.A(2) β€” criminal charges

Disclosure Type Frequency (Yes Answers)

11.D(2) Regulatory
78,706
11.D(4) Regulatory
66,833
11.E(2) Civil
66,128
11.C(2) Regulatory
51,769
11.C(5) Regulatory
49,442
11.C(4) Regulatory
48,023
11.A(2) Criminal
13,711
11.E(1) Civil
11,098
11.A(1) Criminal
7,306
11.B(1) Criminal
6,993

What These Items Mean

Item 11.D covers regulatory actions taken by the SEC, CFTC, exchanges, or self-regulatory organizations β€” the most common category. Item 11.E covers civil court injunctions and orders. Items 11.A–11.B cover criminal indictments, pleas, and convictions. The high counts for 11.D(2) and 11.D(4) reflect many large broker-dealers registering as dual registrants (both IA and BD), carrying their broker-dealer enforcement history.

Firms with the Most Disclosure Items

Large broker-dealer dual-registrants dominate β€” their large networks of registered reps generate many individual DRP events that roll up to the firm level.

#Firm NameDisclosure ItemsType
1Merrill Lynch, Pierce, Fenner & Smith Inc.12,958Broker-Dealer / IA
2Wells Fargo Clearing Services, LLC11,772Broker-Dealer / IA
3Stifel, Nicolaus & Company, Incorporated6,165Broker-Dealer / IA
4J.P. Morgan Securities LLC5,593Broker-Dealer / IA
5Deutsche Bank Securities Inc.4,626Broker-Dealer / IA
6Wells Fargo Advisors Financial Network, LLC4,517IA / BD Network
7Morgan Stanley Smith Barney LLC4,434Broker-Dealer / IA
8Goldman Sachs & Co. LLC4,094Broker-Dealer / IA
9Harbour Investments, Inc.3,737IA
10Credit Suisse Securities (USA) LLC3,568Broker-Dealer / IA

05Institutional Holdings: Form 13F

Form 13F requires institutional managers with $100M+ AUM to disclose all long equity positions each quarter. The database contains 17,489 filings from 6,215 unique advisers, covering 6.75 million individual position records.

6,215
Firms Filing Form 13F
11.1% of all registered advisers
17,489
Total 13F Filings
Across all quarters in database
6.75M
Individual Holding Records
Individual position entries
$545B
Largest Single Position
Reported across all filings

Most Held Securities (by Aggregate Reported Value)

Summing the declared value of each issuer across all filers and periods reveals the securities that dominate institutional portfolios. iShares (BlackRock's ETF brand) tops the list as a wrapper holding billions in underlying equities.

#IssuerAggregate Reported ValueCategory
1iShares TR$6.58 TrillionETF Family
2MICROSOFT CORP$4.99 TrillionTechnology
3NVIDIA CORPORATION$4.79 TrillionSemiconductors
4APPLE INC$4.63 TrillionTechnology
5ALPHABET INC$3.63 TrillionTechnology
6AMAZON COM INC$2.70 TrillionTechnology / Retail
7SPDR S&P 500 ETF TR$2.53 TrillionETF
8META PLATFORMS INC$1.91 TrillionTechnology
9VANGUARD INDEX FDS$1.84 TrillionETF / Index Funds
10BROADCOM INC$1.83 TrillionSemiconductors

The Magnificent Seven Dominates Institutional Portfolios

Six of the top 10 most-held securities by aggregate value are Big Tech β€” Microsoft, NVIDIA, Apple, Alphabet, Amazon, and Meta. Combined, these six account for over $22.7 trillion in reported institutional holdings. NVIDIA's $4.79T position is particularly striking given that its market cap was under $1T just two years prior, illustrating how quickly AI-driven momentum reshapes institutional allocation.

Largest Single Reported Position

$545B

The single largest position reported in any 13F filing in the database. This reflects Vanguard's or BlackRock's internally-held index fund positions, where a single ETF or fund can represent hundreds of billions.

13F Coverage

Of the 56,107 registered advisers, only 6,215 (11.1%) are large enough to trigger the $100M 13F threshold. These firms punch well above their weight β€” managing the vast majority of institutional assets.

11.1% file 13F 88.9% below threshold 6.75M position records

06Part 2A Brochures: What Firms Say About Themselves

Unlike Part 1's structured checkboxes, Part 2A is a narrative document where firms describe their strategies, fees, risks, and conflicts of interest in plain English. The database currently holds 2,676 brochures extracted from SEC FOIA bulk downloads.

2,676
Part 2A Brochures Loaded
Full text extracted from SEC FOIA ZIPs
2,007
Brochures with Brokerage Disclosures
Item 12 β€” naming custodians & brokers

Custodians Most Referenced in Brokerage Sections

From analysis of Item 12 (Brokerage Practices) across available brochures, a handful of custodians dominate the RIA custody landscape:

Charles Schwab & Co. Fidelity Investments TD Ameritrade / Schwab Pershing LLC Interactive Brokers Raymond James National Financial Services

Why Item 12 Matters

Item 12 (Brokerage Practices) is one of the most consequential sections of any investment adviser's brochure. It discloses soft dollar arrangements (where advisers receive research or services in exchange for directing client trades to specific brokers), custodian recommendations, and any directed brokerage that may not represent best execution. Regulators scrutinize this section closely.

07Notable Records & Extremes

Every large dataset has outliers. Here are some of the most striking data points found across the Form ADV universe.

Most Client Accounts

88,400,000

The registered adviser with the highest reported client count serves 88.4 million accounts β€” characteristic of a massive fund supermarket or robo-adviser platform serving retail investors at scale.

Average Clients per Firm

16,572

Total reported clients: 117 million across all advisers. The distribution is heavily right-skewed β€” most boutique RIAs serve dozens to hundreds of clients while a handful of mega-platforms serve millions.

Largest 13F Position

$545 Billion

The single largest individual position reported in any 13F filing. This occurs when a mega-fund manager reports their internally-held ETF position at total fund NAV β€” a single line item representing hundreds of underlying holdings.

Disclosure Concentration

11.6%

Despite the high total disclosure count (548K records), only 11.6% of firms have any affirmative Item 11 answer. The skew toward large broker-dealers means the majority of boutique RIAs have clean records.

On DRP Monetary Amounts & Named Individuals

Form ADV Item 11 captures whether events occurred, not the dollar amounts or individual names involved. For granular enforcement data β€” specific fine amounts, named individuals, case descriptions β€” the SEC's full EDGAR enforcement database and individual Disclosure Reporting Pages (accessible through IAPD search) contain the detailed narratives. The largest SEC enforcement actions typically involve billions in penalties: the Goldman Sachs 1MDB settlement ($2.9B), Allianz Global Investors ($6B), and various LIBOR manipulation cases each exceeded the largest structured fine amounts in SEC history.

08Data & Methodology

All data in this analysis comes from publicly available SEC filings, downloaded and parsed into a local SQLite database.

Data Sources

SEC IAPD Bulk Download EDGAR FOIA Bulk ZIPs 13F EDGAR Filings Form ADV Part 2A PDFs

Form ADV Part 1 structured data downloaded from the SEC's bulk IAPD dataset. Part 2A brochures extracted via pypdf from SEC FOIA bulk ZIP archives (84 ZIPs, approx. Dec 2019–Dec 2024). 13F filings parsed from EDGAR full-text submission files.

Database

SQLite (1.2GB) with tables:

firms (56,107 rows) firm_disclosures (548K rows) firm_brochures (2,676 rows) form_13f_submissions (17,489 rows) form_13f_holdings (6.75M rows)

This analysis reflects data as of June 2026. AUM figures are as self-reported on the most recent Form ADV filing for each firm. Regulatory AUM (RAUM) per Item 5.F may differ from commercially advertised AUM. Brochure coverage is partial (2,676 of 56,107 firms). 13F data covers filings available through the EDGAR bulk dataset. All data is publicly available from the SEC.

09How This Was Built

None of these numbers came out of a spreadsheet. This analysis is a by-product of an engineering project — a unified data pipeline, a Model Context Protocol (MCP) server, and a pair of locally fine-tuned language models that together turn three disconnected SEC datasets into something an AI agent can query directly.

3 → 1
SEC Sources Unified
Part 1 + Part 2A + 13F, joined on CRD
7
MCP Tools Exposed
search, lookup, disclosures, brochures, 13F…
2
Fine-Tuned LLMs
QLoRA adapters trained on the dataset
6GB
GPU Used to Train
4-bit quantization on a single laptop

The Pipeline

A polite, resumable downloader pulls the SEC bulk files — rate-limited and identified, respecting fair-access rules — then unzips and streams them through a pandas transform layer into the database. The 6.75M 13F holdings load in 10,000-row chunks. Everything joins on the CRD number, the one identifier shared across every filing.

The Store

A 1.2GB SQLite build with FTS5 full-text search for local work, and a Postgres path for production — same schema, same loader, swapped underneath.

SQLite + FTS5 PostgreSQL pandas ETL

The Stack

FastMCP Python SQLite / FTS5 PostgreSQL FastAPI QLoRA · TinyLlama PyTorch Docker

The Model Context Protocol Layer

The point of the build is that the data is shaped for an AI agent, not a human clicking around. Seven MCP tools — search_advisers, get_adviser, get_disclosures, get_brochure, get_13f_holdings, stats, and a read-only query_sql — let any MCP-aware client (Claude, Cursor, and others) ask questions of all 56,107 firms without a bespoke scraper. Two TinyLlama-1.1B models, fine-tuned with QLoRA on Q&A pairs generated from the live database, answer ADV questions on hardware I own — one general adapter, one specialized for reading disclosures.

Read the Full Technical Write-Up

This was the data-analysis half of the project. The engineering half — the architecture, the design decisions, and the roadmap for where it goes next — is written up on my portfolio: Regulatory Lens →