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What information must be included in Appendix 1?


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While considered separate documents, Part 2A of Form ADV and Appendix 1 will contain similar language and details. Appendix 1 must contain specific information about the wrap-fee program. It does not need to contain information regarding other programs offered by the registered investment adviser, such as information which must be contained in Part 2A of Form ADV. A registered investment adviser must provide enough information to meet the minimum requirements listed in the instructions to Appendix 1.

According to the instructions, the Appendix 1 must contain a cover page and table of contents. Other requirements include providing a description of the fees charged under the program, a description of the portion of fees provided to persons providing services under the program, and the services provided. Conflicts of interest and other material arrangements must also be disclosed in Appendix 1. Click here to access the instructions of Appendix 1.

Sponsors of wrap-fee programs may use the same Appendix 1 brochure to disclose multiple programs offered by the firm. When a firm uses only one brochure per program, disclosure must be included that the firm sponsors other wrap-fee programs described in separate brochures.

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