Why Our ADV-2 Has So Few Disclosures — And Why That’s a Good Thing

When prospective clients review an advisor’s Form ADV-2, they often expect to see a long list of disclosures. In many cases, those disclosures detail outside compensation, affiliations, commissions, or potential conflicts of interest.

But when people review our firm’s ADV-2, they often notice something unusual.

There isn’t much to disclose.

That’s not an oversight. It’s intentional.

What an ADV-2 Disclosure Actually Means

The Form ADV-2 is the document registered investment advisers provide to clients that outlines:

• Business practices
• Compensation arrangements
• Potential conflicts of interest
• Outside affiliations and licensing
• Disciplinary history

Many firms have long disclosure sections because they participate in multiple business relationships that can create conflicts.

Those relationships might include:

• Insurance commissions
• Brokerage affiliations
• Third-party asset management programs (TAMPs)
• Revenue sharing arrangements
• Proprietary products

Each one requires disclosure because they may influence how advice is given.

Our Structure Is Intentionally Simple

Our firm operates with a structure designed to minimize conflicts of interest from the start.

Here are the key facts about our practice:

No Hidden Licensing or Side Businesses

Lucas holds no additional licenses outside of the advisory business.

I maintain an insurance license solely for the occasional long-term care policy, when it is appropriate for a client’s planning needs. That license exists because sometimes insurance is part of a retirement plan — but it is not a core business line for our firm.

There are no brokerage affiliations, no proprietary product requirements, and no sales quotas.

We Don’t Use TAMPs

Many advisory firms outsource portfolio management to Turnkey Asset Management Platforms (TAMPs).

TAMPs can provide convenience, but they also introduce another layer of fees and business relationships that must be disclosed.

Our firm does not use TAMPs.

Instead, we maintain full independence over the portfolios we build for clients.

Independent Research — Not Product Providers

Another common conflict in the industry comes from research provided by companies that also sell financial products.

When the research provider benefits from the sale of the product being recommended, the incentive structure becomes questionable.

We take a different approach.

We pay for independent research from firms whose only business is selling research — not investment products.

That distinction matters.

It means the firms providing research are not compensated based on what investments we choose.

Their job is simply to provide analysis and data.

We Are Beholden to No One

The goal of our structure is simple:

Remove as many potential conflicts as possible.

No TAMPs.
No product quotas.
No proprietary funds.
No outside compensation arrangements driving decisions.

Just independent advice based on research and experience.

When clients read our ADV-2 and notice the lack of disclosures, the reason is straightforward:

We intentionally built the firm that way.

And in an industry where conflicts can be common, we believe independence still matters.

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Mike Mickels is the President and Chief Compliance Officer of CochranMickels Retirement Specialists, LLC, and an avid sporting clay competitor. Our firm provides personalized planning and investment services to individuals approaching and in retirement. Disclaimer: This content is intended solely for informational purposes. CochranMickels Retirement Specialists, LLC and its representatives are only authorized to offer advisory services where properly licensed or exempt from licensure. Investing carries risks, including potential loss of principal capital. Our firm does not endorse external links, nor is it responsible for third-party content.

Want to learn more? Call us at 256-417-4870 or 407-220-1040.