How to Fill Out Georgia Investment Adviser Registration (Form ADV) + FAQs

Georgia investment adviser registration is the process of completing and filing Form ADV through the Investment Adviser Registration Depository (IARD) so your advisory firm can legally charge clients for investment advice in Georgia. Any firm with its principal office in Georgia that manages less than $100 million in assets must register with the Georgia Securities Division under the Georgia Uniform Securities Act of 2008.

If you skip this step or fill the form out wrong, you cannot legally collect advisory fees, and you risk a cease-and-desist order, fines, or a rejected application that still keeps your $250 fee. The form looks long, but it follows a clear path once you know what each box wants and why the state asks for it. The current Uniform Form ADV carries an April 2022 revision date, so confirm you are using that version before you start.

Here is a number that shows why care matters: state regulators reject or return a large share of first-time adviser applications for missing brochures, blank fee disclosures, or unfunded accounts, and each fix can add weeks to your approval. This guide walks you through every part of the form so you file it right the first time.

• 📋 How to set up your FINRA Entitlement and IARD account before you touch Form ADV.
• 🧾 A line-by-line walkthrough of Form ADV Part 1 and Part 2, box by box.
• 💵 The exact fees, payment methods, and where audited balance sheets get mailed.
• 👥 Three real filer scenarios that show what to enter from start to finish.
• ⚠️ The field-level mistakes that get applications returned, and how to dodge each one.

What Form ADV Is and Who Must File It

Form ADV is the Uniform Application for Investment Adviser Registration. It is the single document that both the SEC and every state, including Georgia, use to register and oversee investment advisers. The form is filed online through IARD, a system run by FINRA on behalf of regulators. When you select Georgia as your registration state inside IARD, the system routes your filing straight to the Georgia Securities Division.

You must file Form ADV in Georgia if you give investment advice for compensation, your principal place of business sits in Georgia, and you manage less than $100 million in assets. Advisers at or above $100 million register with the SEC instead and only “notice file” in Georgia. The registration duty comes from O.C.G.A. § 10-5-32, the section of the Georgia Uniform Securities Act of 2008 that requires registration before you transact advisory business.

The rules that tell you how to apply live in Rule 590-4-4-.02, which spells out the initial application steps. The fee schedule comes from O.C.G.A. § 10-5-39. If you violate the registration requirement, the Commissioner can deny your application and keep your fee, and you may face enforcement action. A common misconception is that a small one-person shop is exempt; in truth, a solo advisor charging fees is usually the exact person who must register.

Federal-covered advisers, who are SEC-registered, do not “register” in Georgia but must notice file through IARD once they pass a client threshold. The two paths use the same system but trigger different fees and forms. Knowing which path you are on is the first decision you make.

Path	Who It Applies To
State registration (Form ADV full filing)	Georgia-based firms under $100M in assets under management
Federal-covered notice filing	SEC-registered firms with more than 6 Georgia clients

Before You Start: Documents and Information You Need

Gathering your details first saves you from saving a half-finished filing and losing your place. IARD does not let you submit a partial Form ADV, so a missing number stops the whole process. Collect these items before you log in.

• Firm legal name and any DBA. This must match your state business filing exactly, because the Division cross-checks your name against corporate records, and a mismatch triggers a processing hold.
• CRD number (if you have one). New firms get one during entitlement; an existing CRD speeds the link, and using the wrong one attaches your filing to another entity.
• Employer Identification Number (EIN). The IRS-issued EIN identifies your firm for tax and regulatory purposes, and a wrong EIN can flag your filing for review.
• Business address and phone. A physical principal office address is required; a P.O. Box alone will not satisfy the “place of business” field.
• Assets under management (AUM) figure. Your current AUM decides whether you register with Georgia or the SEC, so an inflated number can route you to the wrong regulator.
• Fee schedule details. You must disclose how you charge (percentage of assets, hourly, fixed), and a vague answer leads to a returned Part 2 brochure.
• Disciplinary and criminal history. Every “yes” answer needs a Disclosure Reporting Page, and hiding an event is grounds for denial and later enforcement.
• Form ADV Part 2A and 2B brochures. These plain-English documents must be drafted before filing, because Georgia will not approve a firm with no brochure on file.
• Series 65 exam result (or qualifying designation). Each adviser must show competency, and an unfinished exam blocks the individual’s IAR approval.
• Audited balance sheet (only if you hold assets or charge over $500 in advance). This proves solvency and is mailed separately to Macon.

If any item is missing, your filing stalls at that field. Treat this list as a pre-flight check and confirm each piece before you open IARD.

Where to Get the Form and How to Access It

You do not download Form ADV and mail it in. Georgia requires the form to be completed and filed electronically through IARD, the system at iard.com operated by FINRA. The reference copy of the Form ADV PDF lives on the SEC site so you can read the questions ahead of time, but the real filing happens inside the web system.

Before you can reach Form ADV, you must complete the FINRA Entitlement Process to create an IARD user account. During entitlement, your firm names a Super Account Administrator (SAA), the person who controls access and submits filings. After FINRA approves the entitlement, the SAA logs into the FINRA Firm Gateway and can open the electronic Form ADV.

You also must fund your IARD account before submitting, because the system pulls all fees from your account balance at filing. For Georgia state registrants under $100 million, the IARD initial system set-up fee has been waived, but your $250 state filing fee and per-IAR fees still must sit in the account. If the balance is short, the system rejects the submission and your effective date slips.

A common mistake is starting Form ADV before entitlement is approved, then waiting days with a half-built profile. Begin entitlement first, fund the account second, and open Form ADV third. That order keeps your filing moving.

Step-by-Step: How to Fill Out Form ADV Line by Line

Form ADV has two main parts. Part 1 is a check-the-box regulatory form completed inside IARD. Part 2 is a written narrative brochure you upload as a document. Below, each major item gets its own walkthrough in the order it appears.

Item 1: Identifying Information

This item asks for your firm’s full legal name, any business name (DBA) you use with clients, your main office address, phone, fax, and website.

To answer it, type your firm’s legal name exactly as it appears on your Georgia corporate filing, then list any DBA in the separate name field. Enter the physical street address of your principal office, not a mailing box.

For example, Peachtree Wealth Advisors, LLC enters its name in the legal-name box and Peachtree Wealth as the DBA, with a street address of 1100 Peachtree St NE, Atlanta, GA 30309.

A common edge case is the home-based solo advisor; you may use your home address as the principal office, but it becomes public on your brochure, so plan for that exposure.

The most common mistake here is entering a trade name in the legal-name field, which creates a mismatch with state corporate records and triggers a hold while the Division verifies your entity.

People often think the legal name and the marketing name are the same; they are not, and mixing them up delays approval.

Item 2: SEC Registration / State Path

This item asks whether you must register with the SEC or with the state, and it routes your application to the right regulator.

To answer it, you check the basis for your registration; a Georgia firm under $100 million in assets selects state registration and lists Georgia as a state in Item 2.C.

For example, Maria Chen of a $40 million firm checks the state-registration boxes and selects Georgia so IARD sends the filing to the Securities Division.

An edge case arises near the $100 million line; firms between $100 million and $110 million have a buffer rule, so read the SEC thresholds before you choose.

The common mistake is checking SEC registration when your assets fall below the line, which sends your filing to the wrong regulator and forces a withdrawal and refiling.

Many filers wrongly believe they can pick either regulator; the asset threshold decides for you, and guessing wastes the $250 fee.

Item 5: Information About Your Advisory Business

This item asks how many clients you have, how much you manage, the types of clients you serve, and how you charge fees.

To answer it, enter your regulatory assets under management as a current dollar figure, report your client count by category, and check every compensation method you use.

For example, Peachtree Wealth Advisors enters $40,000,000 in regulatory AUM, reports 85 individual clients, and checks “percentage of assets under management” and “fixed fees.”

A frequent edge case is the new firm with zero current clients; you enter 0 AUM and explain your fee model, and the state still registers you as a startup adviser.

The most common mistake on this item is reporting AUM that conflicts with your Part 2 brochure, and the Division flags the gap, which returns your application for correction.

People often assume AUM means total household net worth; it means only the assets you actually manage on a continuous basis, and overstating it can route you to the SEC by error.

Item 8: Participation in Client Transactions

This item asks whether you or a related person have conflicts of interest, such as recommending securities you own or earning commissions.

To answer it, check “yes” or “no” for each conflict question, and if you answer “yes,” describe the conflict in your Part 2A brochure.

For example, Davis Capital Planning checks “yes” because the owner also sells insurance, and the firm describes that commission conflict in its brochure.

An edge case is the fee-only firm that earns no commissions; you check “no” across the board, but you still describe how you avoid conflicts.

The common mistake is checking “no” while your brochure later admits a conflict, and that contradiction is a top reason Georgia returns filings.

Filers often think disclosing a conflict will get them denied; in truth, full disclosure is allowed, and hiding the conflict is what triggers enforcement.

Item 9: Custody

This item asks whether you hold or have access to client funds or securities, which is one of the most scrutinized questions on the form.

To answer it, check “yes” only if you actually take custody, such as deducting fees directly from client accounts or holding assets; most small advisers check “no.”

For example, Maria Chen’s firm uses a third-party custodian and never holds assets, so she checks no custody.

An edge case is direct fee deduction; pulling your advisory fee from a client account can count as custody in some readings, so confirm the rule before you answer.

The common mistake is checking “no” while charging more than $500 in fees six months or more in advance, which under Georgia practice requires you to mail an audited balance sheet, and skipping it stalls approval.

People wrongly assume custody only means physically holding cash; access to client accounts can also count, and a wrong answer here invites an audit.

Item 11: Disclosure Information

This item asks about criminal, regulatory, civil, and financial events in your firm’s and your principals’ history.

To answer it, answer each question truthfully, and for every “yes,” complete the matching Disclosure Reporting Page (DRP) with full details.

For example, Marcus Bell discloses a ten-year-old misdemeanor on a DRP, explains it fully, and his application proceeds with that record on file.

An edge case is an expunged or dismissed charge; many disclosure questions still require a “yes,” so when in doubt, disclose and explain.

The most serious mistake on the entire form is answering “no” to hide a true event, because the Division cross-checks records, and a false answer is grounds for denial and possible fraud charges.

People often believe a minor or old event will sink their application; most disclosed events are reviewed and accepted, while concealment almost always causes denial.

Form ADV Part 2A: The Firm Brochure

Part 2A is the written brochure that explains your firm in plain English, covering services, fees, conflicts, disciplinary history, and your advisory process.

To complete it, write each numbered item as a clear narrative, upload it as a text-searchable document in IARD, and keep the language at a level a client can read.

For example, Davis Capital Planning writes a fee section stating it charges 1.00% of assets under management, billed quarterly in arrears.

An edge case is the firm with multiple service lines; you describe each service and its fee separately so clients see exactly what they pay for.

The common mistake is leaving the fee section vague or copying a template without editing it, which the Division returns because the brochure must match your actual Item 5 answers.

Filers often think the brochure is marketing; it is a disclosure document, and salesy language without real disclosure gets it rejected.

Form ADV Part 2B: The Brochure Supplement

Part 2B is the supplement that describes each individual who gives advice, listing education, work history, exams, and any discipline.

To complete it, write one supplement per advising person, include their formal education and the past five years of business experience, and note their Series 65 or qualifying designation.

For example, Maria Chen’s supplement lists her CFP designation, her Series 65 pass, and her prior role at a brokerage.

An edge case is a brand-new advisor with little history; you state the exam passed and current role, and “other business activities” if any.

The common mistake is omitting a supplement for a part-time advisor, which leaves an advising person undisclosed and returns the filing.

People wrongly think only owners need a supplement; every person who gives advice needs one, regardless of title.

Three Filled-Out Examples Using Real Scenarios

Seeing a full path helps the form make sense. Below are three common Georgia filers walked from start to finish.

Scenario 1: Maria Chen, solo fee-only advisor with $40M AUM (state registration).

Form Section	What Maria Enters
Item 1 Legal Name	Chen Financial Planning, LLC
Item 1 Address	200 Galleria Pkwy, Atlanta, GA 30339
Item 2 Registration Basis	State registration, selects Georgia
Item 5 Regulatory AUM	$40,000,000
Item 5 Fee Type	Percentage of assets under management
Item 9 Custody	No (uses third-party custodian)
Item 11 Disclosure	No events, no DRP needed
Part 2B Supplement	CFP, Series 65 passed
Fee Paid in IARD	$250 firm + $250 IAR

Scenario 2: Davis Capital Planning, two-person firm charging advance fees over $500.

Form Section	What Davis Enters
Item 1 Legal Name	Davis Capital Planning, LLC
Item 2 Registration Basis	State registration, Georgia
Item 5 Regulatory AUM	$22,000,000
Item 5 Fee Type	Fixed fees billed in advance
Item 8 Conflicts	Yes (owner sells insurance)
Item 9 Custody	Yes (advance fees over $500)
Audited Balance Sheet	Mailed to Macon office
Part 2A Brochure	Discloses insurance commission conflict
Fee Paid in IARD	$250 firm + $250 each IAR

Scenario 3: Summit Advisors, out-of-state SEC-registered firm crossing 6 Georgia clients (notice filing).

Form Section	What Summit Enters
Item 1 Legal Name	Summit Advisors, Inc.
Item 2 Registration Basis	SEC-registered, federal covered
State Selected in IARD	Georgia (notice filing)
Item 5 Regulatory AUM	$650,000,000
Georgia Client Count	7 clients
Filing Type	Notice file, not full registration
Part 2 Brochure	Already on file from SEC registration
Initial Notice Fee	$250
Annual Notice Fee	$100

These three cover the most frequent Georgia situations: the solo state registrant, the small firm with custody issues, and the federal-covered notice filer.

How to File the Completed Form

Georgia accepts the Form ADV filing through one electronic channel, with one mailed item in special cases. Below is each step and what proof to keep.

Online through IARD (the required channel). You submit Form ADV Part 1, upload Part 2A and 2B, and authorize fee payment inside the FINRA Firm Gateway. The state filing fee is $250 for the firm and $250 per investment adviser representative at initial filing, drawn from your funded IARD account. IARD accepts payment only from your prefunded account balance, so transfer funds by check or wire to FINRA ahead of time. Processing typically runs several weeks while the Division reviews your file, and you should save the IARD submission confirmation and filing ID as your proof of filing.

Fingerprint submission (for each IAR). Each adviser submits fingerprints with a processing fee of about $52.90. The ORI/OAC number is GA922974Z and the verification code is 922974Z. Out-of-state residents mail three completed fingerprint cards to the Georgia Securities Division, 237 Coliseum Drive, Macon, GA 31211, with a certified check or money order of $46.75 payable to the Georgia Bureau of Investigation.

Audited balance sheet by mail (only if you have custody or charge over $500 in advance). Mail it to the Georgia Securities Division at 237 Coliseum Drive, Macon, GA 31217-2440. Keep your certified-mail receipt as proof.

After you submit and fund, the Division reviews and either approves, requests corrections, or denies. Keep every confirmation until your registration shows approved.

What Happens After You File

Once you submit your funded Form ADV, the Georgia Securities Division reviews your Part 1 answers and your brochures. Reviewers check that your AUM matches your fee disclosures, that every “yes” has a Disclosure Reporting Page, and that your brochure is complete. If something is off, you receive a deficiency notice asking for corrections.

If your filing is clean, the Division approves your registration, and your status in IARD changes to “approved” or “registered.” Only then may you legally charge clients for advice in Georgia. Charging fees before approval violates O.C.G.A. § 10-5-32 and can lead to enforcement.

A common misconception is that filing equals approval; it does not, and acting as an adviser during the review window is a violation. Watch your IARD inbox and email for deficiency letters, because the clock on your application can pause until you respond. Once approved, you move into the renewal cycle described below.

Mistakes to Avoid When Filling Out the Form

Small slips on Form ADV cause most delays. Watch for these specific errors.

• Entering a DBA in the legal-name field, which mismatches state records and triggers a verification hold.
• Reporting AUM that conflicts with your Part 2 brochure, which returns the application for correction.
• Checking SEC registration when you fall below $100 million, which routes you to the wrong regulator and forces refiling.
• Answering “no” to a disclosure question to hide an event, which is grounds for denial and possible fraud charges.
• Checking “no custody” while charging more than $500 in advance fees, which stalls approval until the balance sheet arrives.
• Uploading a vague or template brochure, which the Division rejects for missing real disclosures.
• Forgetting a Part 2B supplement for any advising person, which leaves an adviser undisclosed.
• Starting Form ADV before FINRA entitlement is approved, which wastes days with a half-built profile.
• Submitting with an underfunded IARD account, which causes the system to reject the filing.
• Using a P.O. Box as the principal office, which fails the place-of-business requirement.
• Skipping fingerprints or sending the wrong ORI code, which blocks the IAR approval.
• Missing the December 31 renewal deadline, which lets your registration lapse and forces you to stop advising.

Do’s and Don’ts

A few habits keep your filing clean and your registration in good standing.

Do’s

• Do complete FINRA entitlement first, because it controls all access to Form ADV.
• Do fund your IARD account before submitting, since fees are pulled at filing.
• Do match your AUM and fees across Part 1 and Part 2, because reviewers compare them.
• Do disclose every event with a DRP, since concealment is the top cause of denial.
• Do write your brochure in plain English, because it is a client disclosure, not marketing.
• Do save every confirmation and filing ID, since they are your proof of filing.

Don’ts

• Don’t charge clients before your status shows approved, because that violates state law.
• Don’t guess your registration path, since the asset threshold decides it for you.
• Don’t copy a brochure template without editing, because mismatches get returned.
• Don’t use a P.O. Box as your principal office, since it fails the address rule.
• Don’t ignore a deficiency notice, because your application clock can pause.
• Don’t miss the December 31 renewal, since a lapse forces you to stop advising.

Pros and Cons of Filing on Your Own vs. With Help

Many advisers debate whether to self-file or hire a compliance consultant. Here is how the two compare.

Pros of self-filing

• Saves the $2,000 to $5,000 a consultant often charges, because you do the work.
• Builds your own knowledge of Form ADV, which helps with future amendments.
• Gives you full control of timing, since no third party sets your pace.
• Keeps your fee disclosures in your own words, which reflects your real practice.
• Avoids sharing sensitive financials with an outside firm.

Cons of self-filing

• Higher risk of a deficiency notice, because first-timers miss subtle items.
• Longer learning curve, since IARD and Form ADV are detailed.
• Easy to mismatch Part 1 and Part 2, which returns the filing.
• No expert to draft a compliant brochure, which is the hardest piece.
• Time spent filing is time away from clients, which has its own cost.

Self-Filing	Filing With a Consultant
Lower cost, higher time and error risk	Higher cost, lower error risk
Best for simple solo fee-only firms	Best for firms with custody or conflicts

FAQs

Do I have to register in Georgia if I manage less than $100 million?

Yes. A Georgia-based firm under $100 million in assets registers with the Georgia Securities Division through Form ADV in IARD, not with the SEC.

Do I file Form ADV on paper?

No. Georgia requires Form ADV to be filed electronically through IARD; only the audited balance sheet is mailed when custody applies.

Do I write my legal name or my DBA in the Item 1 name box?

Yes, use your exact legal entity name in the legal-name field, and put any marketing name in the separate DBA field to avoid a records mismatch.

Do I check “yes” on custody in Item 9 if I deduct fees from accounts?

Yes, direct fee deduction can count as custody, and charging over $500 in advance fees triggers the audited balance sheet requirement.

Do I report total household net worth as AUM in Item 5?

No. Item 5 wants only the regulatory assets you actually manage on a continuous basis, not your clients’ total net worth.

Do I need a Disclosure Reporting Page for an old dismissed charge in Item 11?

Yes, many disclosure questions still require a “yes” and a DRP even for old or dismissed events, so disclose and explain rather than hide it.

Do I need both Form ADV Part 1 and Part 2 to register?

Yes. Part 1 is the regulatory check-box form and Part 2 is the written brochure; Georgia will not approve a firm missing either piece.

Do I owe a fee if my application is denied?

Yes. Under O.C.G.A. § 10-5-39, the Commissioner keeps your $250 fee even if your filing is denied or withdrawn.

Do I have to pass the Series 65 exam?

Yes, unless you hold a qualifying designation like CFP, CFA, ChFC, PFS, or CIC, which can waive the exam requirement for the individual.

Do federal-covered advisers register or notice file in Georgia?

No, SEC-registered advisers do not fully register; they notice file through IARD once they exceed six Georgia clients, paying a $250 initial notice fee.

Do I have to renew my Georgia registration every year?

Yes. Renewal runs through IARD before December 31, with a $100 firm fee and $40 per IAR, plus an annual Form ADV update.

Do I need to mail an audited balance sheet for a fee-only firm with no custody?

No, a fee-only firm with no custody and no large advance fees does not mail a balance sheet, since the requirement applies only when you hold assets or charge over $500 in advance.

Do I update Form ADV when my business changes?

Yes, you must amend Form ADV promptly for material changes and file an annual updating amendment, and IARs must update Form U4 within 30 days of reportable events.

Do I create my IARD account before or after I start Form ADV?

Yes, complete the FINRA entitlement and create your IARD account first, because you cannot open or submit Form ADV until entitlement is approved and the account is funded.