The Orange Check methodology: how we verify every advisor

TL;DR. The Orange Check is awarded only to financial advisors whose firms pass a document-based review against the fee-only fiduciary standard. Verification examines three primary regulatory sources — Form ADV Part 1, Form ADV Part 2A, and Form CRS — plus the advisor's individual registration record on IAPD and FINRA BrokerCheck. Advisors must earn every verification point; there are no paid shortcuts, no self-attestation tiers, no partial checks. Verification is renewed annually. If an advisor's regulatory filings change in a way that breaks the standard, the Orange Check is suspended until resolved.

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Why the methodology is public

Most "fiduciary directories" verify by trust: the advisor self-reports, the directory accepts. That's not verification. It's listing.

We publish this methodology for one reason: a verification badge is only as good as the auditor's willingness to show their work. If the consumer reading an advisor's profile cannot understand what was checked, the badge is decorative. The goal of the Orange Check is to be the opposite — a badge the consumer can trust because they can verify the verification.

Everything below is the actual process. No aspirational language, no marketing-layer simplifications.

What the Orange Check means, precisely

An Orange Check certifies four things about the advisor's firm:

1. Registered as an Investment Adviser (not only as a broker-dealer) with the SEC or a state securities regulator under the Investment Advisers Act of 1940.
2. Fee-only compensation — the firm and every related party earn income solely from fees paid directly by clients. No commissions, no 12b-1 fees, no product sponsor revenue, no insurance overrides.
3. Fiduciary duty documented in Form ADV Part 2A and confirmed in writing by the advisor at verification.
4. No material unresolved regulatory events in the firm's or advisor's record on IAPD or FINRA BrokerCheck.

That's it. Four things. Every one of them is verifiable against primary regulatory sources; none of them relies on our judgment or taste.

The five-stage verification process

Stage 1 — Application and initial data

The advisor submits their firm's CRD number, IARD number, and the name of the individual seeking verification. We pull the firm's Form ADV directly from the SEC's Investment Adviser Public Disclosure database — never from the advisor. The advisor cannot alter what we review.

Stage 2 — Form ADV Part 1 review

We check the firm's structured filing data for disqualifiers:

• Item 5.E (Compensation Arrangements). The firm must select only "a percentage of assets under management," "hourly charges," "fixed fees," or "other" with an explanation consistent with fee-only. Selections like "commissions," "subscription fees (other than investment advisory)," or "performance-based fees" that indicate commission or product-sales revenue are flagged.
• Item 5.F (Advisory Activities). Reviewed for material conflicts.
• Item 7 (Financial Industry Affiliations). Firm must NOT be registered as a broker-dealer, or a licensed representative of one, or an insurance agency with commission compensation on clients' transactions.
• Item 8 (Participation or Interest in Client Transactions). Reviewed for proprietary-product conflicts.
• Item 11 (Disclosure Information). Any affirmative disclosure of regulatory actions, civil proceedings, or bankruptcies in the past 10 years triggers Stage 5 escalation.

A firm whose Part 1 selects commission-based compensation or discloses broker-dealer affiliation is not eligible. Period.

Stage 3 — Form ADV Part 2A brochure review

Part 2A is the plain-language firm brochure (see What a Form ADV actually tells you). We read every item, but four control the decision:

• Item 4 (Advisory Business). Confirms what the firm does; flags any advisory activity outside the fiduciary scope.
• Item 5 (Fees and Compensation). This is the decisive item.
  • Compensation must be described as paid "solely by clients," "only by clients," or an equivalent formulation.
  • The section must NOT include language such as "in addition to our advisory fee," "may earn commissions," "12b-1 fees," "trail commissions," or "additional compensation" from product sponsors or insurance carriers.
  • Fee structures must be one or more of: AUM percentage, flat retainer, hourly, or project/flat-plan.
• Item 10 (Other Financial Industry Activities and Affiliations). Must not disclose the firm as a broker-dealer or licensed insurance agency earning commissions on client transactions.
• Item 14 (Client Referrals and Other Compensation). Reviewed for revenue-sharing, shelf-space, or third-party compensation arrangements that would distort recommendations.

Any single disqualifier in these four items ends verification. There is no partial Orange Check.

Stage 4 — Form CRS review

The four-page Customer Relationship Summary required under Reg BI since 2020 is the consumer-facing summary. We check consistency with Part 2A and look specifically at:

• "What fees will I pay?" — must match the fee-only structure described in Part 2A Item 5.
• "What are your legal obligations to me?" — must state the firm acts in the client's best interest and is a fiduciary at all times.
• "How do your financial professionals make money?" — must not reference commissions, sales-based compensation, or product revenue.

Stage 5 — Individual advisor record (IAPD + BrokerCheck)

For the named individual seeking verification:

• Current registration status must be "Currently registered" as an Investment Adviser Representative. Individuals registered only as broker-dealer representatives or dually registered are evaluated for the advisory side only; in most cases we require exclusive IA registration at a single fee-only firm.
• Disclosures are reviewed in full. A clean record proceeds. Each disclosure — customer complaint, regulatory action, arbitration, bankruptcy, criminal matter, or civil judgment — triggers manual review. Unresolved regulatory actions, finance-related criminal matters, or patterns of settled customer complaints with the same theme result in denial.
• Firm tenure is considered but not decisive. Short tenures at multiple firms warrant additional context, especially when concurrent with customer complaints.

Stage 6 — Written attestation

The advisor signs an Orange Check attestation stating, in writing:

• They act as a fiduciary on every recommendation to every client, at all times.
• They are compensated solely by client fees and receive no commissions or third-party compensation, directly or through any related party.
• Their firm's Form ADV Part 2A and Form CRS as reviewed are current and accurate.
• They will notify Fiduciary Check within 30 days of any material change to any of the above.

The signed attestation is part of the verification record and is reviewable by consumers on the advisor's profile page.

What disqualifies a firm

Full list, drawn from the five stages above:

• Registered as a broker-dealer or licensed representative of one.
• Licensed insurance agency with commission compensation on clients' transactions.
• Form ADV Part 2A Item 5 discloses commissions, 12b-1 fees, or product sponsor revenue.
• Form ADV Part 2A Item 10 discloses broker-dealer or insurance affiliation earning sales-based compensation.
• Form ADV Part 2A Item 14 discloses revenue-sharing or shelf-space arrangements.
• Form CRS describes commission-based or sales-based compensation.
• Individual advisor has unresolved regulatory actions, finance-related criminal matters, or a pattern of settled customer complaints with the same theme.
• Advisor declines to sign the written attestation.

What does NOT disqualify a firm

So the standard is clear on both sides:

• Having a higher fee schedule than competitors.
• Specializing in a narrow niche (business owners, equity comp, retirees).
• Serving only high-net-worth clients, or serving only middle-market clients.
• Holding or not holding the CFP®, CFA®, CPA, or ChFC® credential. (Credentials are noted on the profile but are not required for the Orange Check.)
• Being a newer firm with limited operating history.
• An isolated old disclosure with a clear resolution (e.g., a 2005 customer complaint resolved in the advisor's favor with no subsequent pattern).
• Operating from a single-advisor office vs. a multi-advisor firm.

The annual renewal

The Orange Check is valid for 12 months from the verification date. Every year, we pull the firm's current Form ADV and the advisor's current IAPD record and re-run every stage above. Nothing is grandfathered.

If the renewal review finds:

• A change in Form ADV that would have disqualified the firm at original verification → Orange Check suspended immediately; profile page displays "Verification under review" until the firm either updates or voluntarily exits.
• A new disclosure on the individual's record → manual review. If material and unresolved, the badge is suspended.
• The attestation conflicts with the Form ADV → the advisor is contacted; discrepancy must be resolved within 30 days or the badge is suspended.

Consumers can see the verification date and next-renewal date on every Orange Check profile.

The public verification record

Every verified advisor's profile page on Fiduciary Check displays:

• Verification date and next-renewal date.
• Which ADV items and CRS sections were reviewed.
• The signed attestation excerpt.
• Direct links to the advisor's live IAPD and BrokerCheck records, so consumers can audit the auditor.

This is the single biggest difference between the Orange Check and a typical pay-to-play directory listing. The verification is designed to be reproducible. A consumer with 10 minutes and a browser can replicate every check we did.

What we don't verify

The Orange Check is a verification of compensation structure and regulatory standing, not a rating of quality, service, or investment performance. Specifically, we do not verify:

• Investment performance. No directory should claim to predict returns. Past performance is disclosed by the firm; we do not judge it.
• Service quality or responsiveness. Consumer reviews are a separate signal; they complement the Orange Check but don't replace it.
• Fit. Whether an advisor is the right fit for a specific consumer depends on specialty, communication style, fee model, and the consumer's own needs. The Orange Check narrows the universe to fee-only fiduciaries; the consumer still chooses within that universe.

The regulatory sources, in one place

For consumers, researchers, or journalists who want to replicate any part of this methodology:

• SEC Investment Adviser Public Disclosure (IAPD) — adviserinfo.sec.gov. Firm and individual records, including full Form ADV Parts 1, 2A, 2B, and Form CRS.
• FINRA BrokerCheck — brokercheck.finra.org. Broker-dealer representative registrations; dual registrations appear here.
• Form ADV instructions and general questions — sec.gov/foia/docs/form-adv.
• Form CRS — sec.gov/form-crs.
• Regulation Best Interest — sec.gov/regulation-best-interest. The broker-dealer standard that applies when the fiduciary standard does not.
• Investment Advisers Act of 1940 — PDF. The foundational statute for investment adviser fiduciary duty.
• 17 CFR §275.204-3 — eCFR. Brochure delivery requirement.
• NAPFA Fiduciary Oath — napfa.org. The professional standard the Orange Check aligns with.
• CFP Board Code of Ethics and Standards of Conduct — cfp.net/ethics. Fiduciary conduct required of CFP® professionals since 2019.

Why this methodology, and not something stricter

We considered stricter standards — for example, requiring every Orange Check firm to also publish fee schedules, or to use only index funds, or to custody exclusively at no-fee platforms. We decided against adding those requirements because they cross from verifying the fiduciary standard into judging good practice. Reasonable fee-only fiduciaries disagree on those questions; their disagreement is not a fiduciary breach.

The Orange Check is narrow on purpose. We verify the structural conditions under which a fiduciary duty can be practiced honestly — fee-only compensation, independent RIA registration, clean regulatory record. Within that structure, advisors differ by specialty, style, and approach. Consumers choose.

Why this methodology, and not something looser

We also considered looser standards — for example, accepting fee-based firms that commit to fiduciary conduct on their advisory work. We decided against it because the fee-based model structurally creates the conflict the fiduciary standard is designed to prevent. An advisor who earns $12,000 in commission on a product sale while charging a 1% advisory fee has, by construction, a compensation incentive that is not aligned with the client's interest — regardless of how carefully they promise to manage it.

The Orange Check exists to give consumers a clear signal. "Some of my compensation aligns with your outcome" is not a clear signal. "Only your fees pay me" is.

How to replicate this check in 30 minutes for any advisor

If you want to verify any advisor — Orange Check or not — run the same process yourself:

1. Look up the advisor on IAPD.
2. Confirm current registration as an Investment Adviser Representative.
3. Open the firm's Form ADV Part 2A brochure.
4. Read Item 5 (Fees and Compensation). Confirm fee-only language and absence of commissions or product revenue.
5. Read Item 10 (Other Activities). Confirm no broker-dealer or insurance agency affiliation.
6. Read Item 14 (Referrals and Other Compensation). Confirm no revenue-sharing.
7. Open Form CRS. Confirm consistency with Part 2A.
8. Read the Disclosures section for both firm and individual.
9. Ask the advisor in writing: "Are you a fiduciary on every recommendation, at all times, with no exceptions, and are you paid only by clients?"

If every answer is yes, you have verified the advisor against the same standard as the Orange Check.

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Key takeaways

• The Orange Check is a document-based audit against the fee-only fiduciary standard.
• Verification examines Form ADV Parts 1 and 2A, Form CRS, and the advisor's IAPD + BrokerCheck record.
• The four Part 2A items that control the outcome: 4, 5, 10, and 14.
• A single disqualifier in any of them ends verification. No partial Orange Check.
• Verification is renewed annually against current regulatory filings; nothing is grandfathered.
• The verification record is public on every advisor's profile so consumers can audit the auditor.

Sources

All primary regulatory sources cited throughout are listed in the "The regulatory sources, in one place" section above, each with a direct link.

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See the methodology applied.

Every advisor in the Fiduciary Check directory has been through the process described in this article. Their verification record is on every profile.

Browse verified fiduciaries →  ·  Are you a fee-only advisor? Apply for verification →

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