Middle Names and Form ADV

When filling out Form ADV, Schedule A and Schedule B require you to disclose control persons, owners, and significant indirect owners of the investment adviser. The instructions call for the full legal name: Last name, first name, and middle name.

And the SEC means it. They require full legal names (last, first, and middle name). If there is no middle name or only a middle initial, the information provided next to the name should reflect as such; (NMN) or (MI ONLY).

Unfortunately, FINRA’s system does not place one of those red stars next to the middle name field indicating that it’s a required field. Similarly, the online IARD filing system’s completeness check does not pick up a missing entry for a middle name.