Advorra blog

Brochure supplements for small RIAs: who needs one, and when to deliver it

By the team at The CollabHub · Co-written with Mohammad Aamish Aaftab
Published 18 Oct 2026

A brochure supplement (Form ADV Part 2B) gives clients information about the individual people who advise them. Under SEC Rule 204-3, an adviser delivers a current supplement for a supervised person before or at the time that person begins providing advisory services to a client. A person provides advisory services if they formulate investment advice for the client and have direct client contact, or make discretionary investment decisions for the client even without contact. Where a team of more than five gives advice, supplements are needed only for the five with the most significant day-to-day responsibility.

Most small firms remember the brochure. The supplement is easier to forget, especially when a new associate starts taking client calls, or an existing person starts making trading decisions on accounts they never used to touch. The rule ties delivery to the moment someone starts serving a client, not to a calendar date.

What is a brochure supplement?

A brochure supplement is Form ADV Part 2B. The brochure (Part 2A) describes the firm. The supplement describes the individual people who advise a client: their background, education and business experience, and other information the form asks for.

Who needs a supplement?

Under the SEC rule, a supervised person provides advisory services to a client if they:

An operations assistant who files paperwork and schedules meetings usually meets neither test. A team of more than five only needs supplements for the five with the most significant responsibility for day-to-day advice to that client.

Source: 17 CFR 275.204-3(b)(3).

When do you deliver it?

The annual delivery requirement in the same rule is about the brochure and its summary of material changes, not the supplement. Source: 17 CFR 275.204-3(b).

A worked example

Take a hypothetical two-person RIA with about 120 households. The owner advises every client and has a supplement that went out at onboarding. The firm hires an associate adviser who will start meeting a group of 30 existing clients and recommending changes.

1. The associate's Part 2B is prepared and reviewed before their first client meeting.
2. It is delivered to each of the 30 clients before or at the first meeting where the associate provides advice.
3. Delivery is recorded per client: date, method, version.
4. New clients from then on get both supplements at onboarding, with the brochure.

How should you record delivery?

• Client, supervised person, supplement version and date delivered.
• Method: email, portal, paper.
• For electronic delivery, keep evidence it was sent.
• Keep the delivered version, not just the latest one.

Common gaps

• A new person starts serving existing clients and no supplement goes out.
• Someone starts making discretionary decisions without client contact, and nobody thinks they need one.
• Delivery is recorded for the brochure but not the supplement.

When is this overkill?

A solo adviser with no staff delivers one supplement, their own, at onboarding. That's a single line on the onboarding checklist, plus a check whenever anything in it changes.

How Advorra fits

Advorra keeps a brochure-delivery log alongside client records and other compliance registers, so delivery dates sit with the client they belong to. See the product page, or read brochure delivery records and your first operations hire.

One thing to do this week: list everyone at your firm who advises clients or makes discretionary decisions, and check each one's supplement went to every client they serve.

A plain summary of public rule text, not legal or compliance advice. State-registered advisers should check their state's rules.