Before hiring or retaining a financial professional, get four answers in writing: which legal capacity they use for each service, what you will pay in total, what incentives could influence recommendations, and whether anyone pays them for a referral. Ask for the current Form CRS, Form ADV Part 2A brochure, and applicable Part 2B supplement, then compare candidates on the same four dimensions. A quoted advisory percentage is only one part of the cost.
Start by identifying the relationship and legal capacity
The same person may provide services as an investment adviser, a broker-dealer representative, or both. The duties, compensation methods, available products, and disclosures can change with the capacity in which the person acts. Ask this before discussing a portfolio recommendation:
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- “Will you act as an investment adviser, broker-dealer representative, or both for each service you provide?”
- “What changes when you act in each capacity?”
- “Which legal entity is my client relationship with, and which entity will send invoices or receive commissions?”
- “Are you and your firm registered with the SEC, a state regulator, or both for the services I am considering?”
Form CRS is a standardized relationship summary for SEC-registered broker-dealers and investment advisers serving retail investors. The SEC describes it as a way to compare brokerage, advisory, or combined relationships, including services, fees, conflicts, disciplinary history, and other key information. The SEC’s Standards of Conduct Implementation Committee described Form CRS on December 17, 2021, as “a brief relationship summary designed to help retail investors make informed choices regarding what type of relationship—brokerage, investment advisory, or a combination of both—best suits a retail investor’s particular circumstances and investment objectives.”
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One free scan finds every outdated or missing driver and matches the right update for your exact hardware.Free scan · exact hardware matchRead the capacity label on every proposal and account document. A professional who is both a broker and an adviser should be able to tell you which hat applies to each recommendation, how the compensation changes, and what standard of conduct applies in that setting.
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Ask for the all-in cost, not just the headline rate
Request an estimate in both dollars and percentages for a typical year. Use the SEC’s own conversation starter: “If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?” The $10,000 figure is a hypothetical prompt, not a reported industry statistic. Ask the professional to show assumptions such as account size, trading frequency, holdings, and service level.
| Cost category | Questions to ask | What to obtain in writing |
|---|---|---|
| Advisory or management fee | “What percentage or flat amount applies at my balance? Are there asset-tier breakpoints or minimums?” | The rate schedule, minimum account size, and whether the fee is negotiable. |
| Commissions and transaction charges | “Will I pay commissions, markups, markdowns, ticket charges, or other trading costs? How often might trades occur?” | A description of each charge and an example based on my expected activity. |
| Fund and product expenses | “What expenses are deducted inside the funds or products you recommend? Are there lower-cost share classes or alternatives?” | Expense information for the products likely to be used and any sales charges or surrender costs. |
| Custody, platform, and account fees | “Who holds the assets, and what account, custody, wire, transfer, statement, or platform fees apply?” | The custodian’s schedule and which charges are paid to the adviser, broker, custodian, or another provider. |
| Planning and add-on services | “What is included in the ongoing fee, and what costs extra—tax planning, hourly consultations, estate work, insurance analysis, or a one-time plan?” | A description of included deliverables, extra rates, and billing triggers. |
| Other expenses | “Are there fees for minimum-balance shortfalls, account termination, transfers, alternative investments, or third-party services?” | All recurring and event-based charges that could affect the account. |
For an investment adviser, Form ADV Part 2A must explain how the adviser is compensated, provide a fee schedule, and disclose whether fees are negotiable. The brochure also describes how and when fees are billed, other client expenses, brokerage practices, referral arrangements, and conflicts. Ask whether fees are deducted from the account, paid by invoice, or charged another way, and whether billing is monthly, quarterly, in advance, or in arrears. Confirm how a partial quarter, withdrawal, termination, or change in account value is handled.
Separate the quoted fee from the amount you actually lose to costs
An adviser charging a percentage of assets may not be the largest source of expense if the account also incurs product, trading, custody, or service charges. Conversely, a commission-based account may have no recurring advisory percentage but can still generate transaction or product costs. Ask the professional to put every expected charge on one page and identify who receives each amount. If the answer is “it depends,” ask for a low, typical, and high illustration tied to your circumstances rather than accepting an unbounded estimate.
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Find out how compensation creates incentives
Compensation can influence what a professional recommends without proving that a recommendation is unsuitable or improper. SEC staff identifies several potential sources of conflicts:
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- Revenue that changes with account type, product, service, or assets under management.
- Commissions, sales loads, markups, or other product-based payments.
- Variable compensation, bonuses, contests, or non-cash awards for production.
- Proprietary or affiliated products that generate revenue for the firm.
- Payments, revenue sharing, expense offsets, gifts, or other benefits from third parties.
- Benefits tied to rollovers, share classes, custodians, or particular account features.
Make every disclosure concrete with the same sequence of follow-ups: What exactly is the incentive? Who receives it—the individual, the firm, an affiliate, or another party? Does the amount change by product, account type, balance, or transaction? How could it affect this recommendation? What lower-cost or unaffiliated alternatives were considered? What mitigation is in place? If the conflict cannot be addressed, what advice will the firm decline to give?
Ask specifically: “Do you or your firm earn more from particular products, account types, rollovers, share classes, custodians, or affiliated businesses?” Then request the answer in writing. A general statement that the firm “may have conflicts” does not tell you which incentive applies to your recommendation or how it is controlled.
Understand what mitigation means
Disclosure is not automatically the same as resolution. SEC staff guidance says firms must address conflicts consistently with the applicable standard of conduct and may need to mitigate or eliminate a conflict, or refrain from advice influenced by a conflict they cannot adequately address. Ask the firm to describe its actual process: supervisory review, product restrictions, compensation limits, neutral product lists, fee offsets, recusal, or declining the recommendation. The useful answer connects the control to the specific incentive rather than reciting a policy title.
Ask directly about referral compensation
A referral can be useful, but it may also create a financial reason to steer you to a particular provider. Ask all four parts of the arrangement:
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- “Who pays you or your firm when I use the referred provider?”
- “What benefit do you receive—cash, revenue sharing, gifts, expense reimbursement, free services, or another form of compensation?”
- “Is the provider affiliated with you or your firm, under common ownership, or otherwise connected?”
- “May I choose a different provider without affecting your service or fee?”
Then ask whether the payment is one-time or recurring, whether it varies by provider or product, and whether the referred provider pays for placement on a preferred list. Ask what alternatives were considered and why the referral fits your circumstances. Form ADV disclosures address client referrals and other compensation and conflict topics, so compare the spoken explanation with the written brochure.
A referral arrangement can involve a provider for custody, insurance, tax, legal, lending, retirement-plan administration, or another service. Clarify whether the professional is giving advice about that service, merely making an introduction, or receiving compensation for both. Request a copy of any referral agreement or disclosure that affects your cost or the professional’s incentive.
Request the documents that let you verify answers
Form CRS
Obtain the current Form CRS for the exact firm and relationship you are considering. Use it to compare services, account minimums, fees, conflicts, disciplinary history, and whether the firm operates as a broker, an adviser, or both. Because it is concise and standardized, treat it as a starting point, not a substitute for the adviser’s fuller brochure.
Form ADV Part 2A
For an investment adviser, Part 2A is the plain-English brochure covering business practices, fees, negotiability, billing, other client expenses, brokerage, referral arrangements, conflicts, and disciplinary information. Check that the version is current and that the fee schedule matches the proposal. Ask the adviser to explain any difference between the brochure and the contract.
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Form ADV Part 2B
Part 2B is the supplement for the specific individuals who provide advice or make investment decisions. Request the applicable supplements for everyone who will materially influence your account. Review their professional background and reportable disciplinary history rather than relying only on the firm-level brochure.
Verification and written answers
Ask where you can verify any reportable disciplinary history in the relevant regulator’s public records. Keep copies of the documents, fee illustrations, and written responses. If an answer is unclear, send a short email summarizing your understanding and ask the professional to correct it before you open the account.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Compare candidates on the same four axes
Use one worksheet for every professional. The goal is consistency, not a particular outcome.
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1Fix the driver behind crashes, sound loss and screen glitches2Repair Windows errors before they cause bigger problems3Scan for outdated or missing drivers - takes under a minute| Comparison axis | Record for each candidate |
|---|---|
| Capacity and scope | Adviser, broker-dealer representative, or both; services included; account types; who is legally responsible. |
| Total costs and billing | Advisory fees, commissions, trading, custody, product expenses, planning charges, minimums, negotiability, billing timing, and estimated annual dollars. |
| Incentives and referrals | Products or accounts that pay more, affiliates, bonuses, third-party benefits, referral payments, alternatives considered, and mitigation. |
| Disclosures and verification | Current Form CRS, Part 2A, applicable Part 2B supplements, disciplinary disclosures, and instructions for checking regulator records. |
Ask each candidate the same questions and provide the same household facts, account size, time horizon, liquidity needs, and service expectations. A lower percentage is not automatically cheaper if it comes with higher product or transaction expenses, and a higher fee is not automatically unreasonable if it includes services you would otherwise purchase separately. Compare the total arrangement and the incentives attached to it.
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A practical interview sequence
- Before the meeting: Download or request the current Form CRS and Form ADV documents. Write down every service you may need, including investment management, planning, retirement-account work, insurance, tax coordination, or referrals.
- At the start: Ask which capacity and legal entity apply to each service. Note who will provide advice, who will manage assets, and who will invoice or receive commissions.
- Build the cost estimate: Use the $10,000 hypothetical prompt, then replace it with your expected balance and activity. Require dollars, percentages, billing frequency, and all pass-through expenses.
- Map incentives: Ask what compensation changes by product, account, rollover, custodian, affiliate, or referral. Ask for the alternatives considered and the control used to address each conflict.
- Test referrals: Identify who pays, what is received, whether the provider is affiliated, and whether you can choose another provider without penalty.
- Close the loop: Request written answers, contracts, fee schedules, and the relevant Part 2B supplements. Do not sign until you can reconcile the documents with the conversation.
Recognize useful answers and warning signs
Answers that improve your ability to decide
- A clear statement of capacity for each service and the entity you contract with.
- A single estimate showing recurring and one-time costs, who receives them, and when they are billed.
- Specific examples of incentives, affected products or accounts, and controls that limit their effect.
- A referral explanation that names the payer, benefit, affiliation, alternatives, and your freedom to choose.
- Current documents supplied without resistance and explanations that match those documents.
Warning signs that require follow-up
- The professional will not identify whether the relationship is brokerage, advisory, or combined.
- The quote includes only the advisory percentage and dismisses product, trading, custody, or referral costs.
- “There are no conflicts” is offered instead of identifying compensation arrangements.
- A referral is presented as mandatory, or the professional cannot say who pays for it.
- Documents are outdated, unavailable, or inconsistent with the verbal explanation.
One warning sign is not proof of misconduct, but an incomplete answer leaves you unable to evaluate the relationship. Pause the decision and request clarification in writing.
Know the limits of the SEC-focused framework
This framework is aimed at U.S. retail relationships involving SEC-registered investment advisers and broker-dealers. State-registered advisers, insurance professionals, tax professionals, retirement-plan providers, and other financial-services arrangements may follow additional or different rules. Ask which entity and professional provide each service, which regulator oversees that activity, and which disclosure document applies.
Fees, conflicts, referral relationships, and firm disclosures are firm-specific and can change. Request current documents immediately before engaging the professional and again when a material service, account, product, or compensation arrangement changes.
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On June 9, 2026, the SEC Division of Examinations announced a risk alert covering advisers’ economic incentives, written policies, fee and expense disclosures, and whether advisory fees and expenses are accurately calculated and charged according to the disclosures. The alert describes examination focus areas; it is not a statistic about how often misconduct occurs. For a consumer, its practical lesson is to reconcile the fee you were promised with the amount actually charged and the policy documents that govern the account.
The decision standard is straightforward: you should know who is being paid, how much you are paying in total, what incentives could influence advice, and what happens when a conflict cannot be adequately addressed. If the professional cannot answer those questions clearly, you have not yet received enough information to consent to the arrangement.
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