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What’s the Point of the Multiple Adviser Disclosure in Form ADV?

05/13/2026

Form ADV, the disclosure document filed with the Securities and Exchanges Commission (SEC) by private fund advisers each year contains a treasure trove of information, and here at 9AT, one of our specialties is aggregating that data and formatting it so that it can be analysed and understood for our clients.

Most people focus on the obvious data points - assets under management, number of funds, fund category, etc. But there are plenty of others, including some that offer a window into the inner workings of an adviser, like the use of multiple investment advisers within a single private fund structure.

Section 7B of the ADV is where advisers provide information specific to each private fund to which they act as an adviser. Within this section, question 18 asks whether any investment advisers beyond those already disclosed elsewhere in the filing also advise the private fund in question. At first glance, this may appear to be nothing burger but in reality, it can provide meaningful insight into how a fund is managed, how responsibilities are allocated, and how the broader private funds market is evolving.

Many of the ‘other advisers’ listed on the form don’t provide significant insights - they’re simply subsidiaries of the parent adviser (think ‘Amazing Capital Management Europe’ being an ‘other adviser’ to ‘Amazing Capital Management 1 LP’, for example). In these cases, the arrangement is entirely routine and reflects the increasing complexity and specialization of modern private markets investing.

But some are more interesting. A multi-strategy hedge fund may allocate different portfolio sleeves to specialist external managers, for example. And a private equity platform may use separate advisory entities for deal origination, sector-specific expertise, or portfolio management functions. In each case, multiple advisers can help improve execution, deepen specialist knowledge, and broaden investment capabilities.

As a result, analyzing this field in the Form ADV has become increasingly valuable, particularly for investors and service providers.

For institutional investors and capital allocators, the presence of multiple advisers can offer insight not only into a manager’s investment model, but their operational model and governance framework as well. Investors conducting due diligence often want to understand precisely who exercises investment discretion, how decisions are made, and whether responsibilities are clearly delineated.

Obviously (you would hope obviously) that this comes up in due diligence meetings with the parent adviser. But while the use of multiple advisers may indicate a sophisticated and institutionalized platform, particularly in large or globally diversified advisers, on the flip side, it may introduce additional complexity around oversight, conflicts of interest, or fee structures, all important considerations for investors looking at placing capital.

For compliance professionals and regulators, the field helps identify how advisory functions are distributed across entities. The SEC has long focused on ensuring that advisers do not obscure control, avoid disclosure obligations, or create undisclosed conflicts through fragmented organizational structures and the information found in this field supports these goals.

The data is also increasingly useful for researchers and market analysts seeking to understand broader industry trends. Changes in the prevalence of multiple-adviser structures can reveal important shifts within the private funds market itself. One example of this is the hedge fund ‘pod shop’ concept. While most people know the brand names in the space, not all pod shops are the same; some don’t have any ‘other advisers’, so the fund is simply an aggregate of many internal portfolio managers, and some do. Data for Form ADVs filed in 2025 suggests that only 114 out of 1,798 hedge funds on the spreadsheet disclose “other managers” so it will be interesting to see if this increases over time.

The existence of multiple advisers should not automatically be interpreted as being either positive or negative. In many cases, it simply reflects the realities of modern private markets investing. The significance lies less in the structure itself and more in what the structure reveals about a fund’s operational approach, strategic ambitions, and governance framework.

But as the private funds industry continues to expand and diversify, operational transparency is growing in importance. The Form ADV is full of data that can offer a glimpse into the inner workings of a fund, and this is just one example.

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