A deep-dive into the SEC’s annual Form ADV filings show two results pertinent to wider fund marketing teams competing for investor attention.
The SEC’s Form ADV applies to the standardised approach for investment advisors to register with the US regulatory and state securities authorities. A new quarterly report from Paithos Research has looked into filings by 14,193 RIAs in both the 2025 and 2026 annual-amendment seasons:
- The median RIA grew AuM by 14.4% in fiscal 2025.
- However, its reported client numbers rose only by 2.1%; a net gain of one client.
- Around a third of firms grew their asset bases despite adding no net clients whatsoever.
It was also found that the gaps in client counts were attributed to scale:
- Firms over $10 billion in AuM grew their client counts at around double the rate of firms holding between $100 million – $1 billion.
- The largest tenth of firms hold 82.5% of all reported clients – a figure up from 80% the year prior.
The surfaced findings into testimonial data also shine a light on the effects of the SEC’s 2021 Marketing Rule, which first allowed compliant client testimonials.
Adoption has grown firm-wide to 11.1% of RIAs. However, taking into account firms that did expand client bases by 10% or more against those that stayed level or shrank, growing firms used testimonials at double the rate – 15.2% vs 7.4%, respectively – and paid for referrals more often as well.
The researchers figure this finding to be an association, not a proof of causation; marketing status and growth were both measured in the same filing year. It is important to note Paithos sells marketing services to advisors, where this conflict is disclosed directly in the report.
So, what does this mean for fund marketers?
While this data concerns RIAs and not private funds, the same mechanism can be generalised to any manager focusing on adhering to allocators to raise AuM.
Organic growth is largely scarce, with funds relying more on specific tools opened up by the Marketing Rule as much as reputation and referrals alone, including testimonials, endorsements or ratings by third parties.
The ability to adopt these means appears to highlight resource gaps for smaller firms (rather than them outright rejecting the tactic). Testimonial use spans from 6% at sub-$100 million firms to 18.4% at those with $10 billion+.
Getting testimonials is not exactly a ‘fix’ for getting new relationships. What this SEC data should highlight is how documented, routine use of disclosure-based tools opened up by the 2021 regulation helps managers compete besides having to rely on existing AuM alone. A Pandora’s Box of opportunity, perhaps!
Source
Paithos Research, The RIA Signals Report — Q3 2026
