Protecting Personal Information in Form ADV Filings

Firms are required to provide complete, up-to-date and accurate information on Form ADV “Filings”.  Some of the information required to complete these Filings is personal information. Please review the following guidance on how to protect this information.

Personal Information Required

As a matter of course, some personal information may be required to complete the Filings. Most required personal information is entered into specific, defined text fields, where the inclusion of such data is expected. This allows for protection of those fields from inadvertent disclosure.

Personal Information May Be Required

Sometimes Filings require that you enter information that in some instances may be personal information. For example, Form ADV Schedule A asks for “S.S.No. and Date of Birth” if a CRD No. does not exist. If “S.S.No. and Date of Birth” are entered in such circumstances, Form ADV provides a means to identify this field as personal information by selecting the “SSN” button next to the field. If the button is selected, this field will be identified as personal information and it will allow for protection from inadvertent disclosure.   

Personal Information Not Required

Filings frequently solicit information in response to a more general question that does not require personal information. For example, Form ADV Schedule D Miscellaneous section is a free text field that allows filers to enter a response in narrative format in order to explain a previous response to an Item or to provide any other information.  When providing a narrative response in a free text field such as this, do not include personal information specific to any individual or account. Instead, use descriptive information that does not include personal information to provide the complete, up-to-date and accurate required response.

Remember to only provide personal information about individuals in response to specific questions that solicit that information. When responding to more general questions that accept narrative responses, use terms that do not disclose personal information.

If you have questions about how to appropriately complete a filing and protect personal information, please contact the SEC, FINRA, or your state securities regulator.