Latest Disclosure Trends in the Form ADV Brochure

September 30, 2025

Stay ahead of the curve with Seward & Kissel’s analysis of Form ADV Part 2A (“Brochure”) filings from leading SEC-registered investment advisers. The report highlights four major disclosure trends shaping the investment management landscape:

  1. Enhanced Management-Related Disclosures
  • Advisers are providing more detail on affiliated services, including collateral management, portfolio monitoring, and due diligence.
  • New disclosures address the use of artificial intelligence and machine learning.
  • Advisory committees and family office structures are increasingly discussed.
  • Bespoke client terms and relationships with outside vendors are receiving greater attention.
  1. Expanded Fund Expense Transparency
  • Technology-related costs, business development activities, and investor meetings are now more frequently disclosed.
  • New categories such as cyber and crime insurance, background investigations, and investor-requested reporting templates are being included.
  • Greater detail on pass-through expense models helps clients understand fund operating costs.
  1. Increased Risk and Conflict of Interest Disclosures
  • Advisers are addressing emerging risks, including digital asset regulation, AI, geopolitical events, climate change, and hybrid work arrangements.
  • Conflicts of interest are more thoroughly disclosed, especially when offering affiliated services or entering new business lines.
  1. Growth in New Investment Strategies and Structures
  • Advisers are expanding into cryptocurrencies, digital infrastructure, CMBS/CLOs, and specialized opportunity funds.
  • New structures such as separately managed accounts, single investor funds, co-investment vehicles, continuation funds, and feeder funds offer greater flexibility for investors.

For more insights or to discuss how these changes may impact your business, contact Seward & Kissel’s Investment Management Group.