AUM, regulatory AUM and Form 13F: why the numbers differ

Start with the entity, the date and the measure

Write down which legal entity each number belongs to, the date it measures and the definition used by its source. A group announcement may describe several businesses. A filing may describe one reporting entity. Even matching names do not establish matching scope.

In RIA Monitor, a source month identifies the retained data snapshot. It does not mean every firm valued its assets on the same day. Keep the underlying reporting dates in view when the distinction matters.

Regulatory AUM follows Form ADV instructions

Regulatory assets under management, or RAUM, is the measure reported in Form ADV Item 5.F. It concerns securities portfolios receiving ongoing supervisory or management services under the form’s instructions. The calculation has specific inclusion and valuation rules; it is not simply whichever asset total appears in a headline.

For a comparison, use the same measure and identify the reporting adviser. Do not substitute a parent company’s total for a subsidiary’s filing, or combine related entities without establishing what overlaps. The SEC’s Form ADV instructions, Part 1A, instruction 5.b explain the calculation.

A group asset figure needs its own definition

“Assets under management,” “assets under advisement” and “assets under administration” are labels to investigate, not interchangeable totals. Read the issuer’s definition, included businesses and measurement date. A combined figure can answer a question about the wider organization without answering the question about one registered adviser.

We keep a profile’s reported regulatory AUM attached to its identified legal entity. When a separate source describes a wider group, that distinction belongs beside the figure.

Form 13F is a holdings report

Form 13F reports qualifying securities holdings and their quarter-end values. Its scope follows the SEC’s Section 13(f) securities list. For example, ordinary open-end mutual fund shares are outside that list, and short positions are not reported. A public holdings total therefore does not describe every asset a manager oversees.

The filing date and quarter-end date are different. A newly available filing can describe positions held months earlier. Use the SEC staff’s Form 13F FAQs, particularly questions 7, 8 and 41, to check the scope. A holdings snapshot alone does not establish trades or investment returns.

Illustrative example: one name, three boundaries

Suppose a group announces $20 billion of assets under management and advisement, one adviser entity reports $12 billion of regulatory AUM, and a matched manager’s 13F reports $4 billion of qualifying holdings. These invented figures are not three amounts to add together. Their populations may overlap, and their dates may differ.

The useful next step is to identify what each source includes. Choosing the largest figure would answer a different question from comparing legal entities using reported regulatory AUM.

Make the comparison you actually need

1. Match the legal entity and its identifier, such as a CRD number.
2. Keep the measurement date separate from the filing or publication date.
3. Compare the same asset measure and inspect the original source.
4. Keep missing amounts separate from reported zero values.

A change in reported AUM does not, by itself, establish organic growth, new client money or performance. Market movements, transactions and reporting changes need separate evidence. Size also does not establish advice quality or suitability for a particular client.

Find an adviser profile and follow its source links, or compare the covered state-size population. Our methodology explains how the directory keeps these measures and their dates separate.