Run it as a diligence exercise. Read the firm’s Form ADV Part 2A brochure and its Form CRS on the SEC’s public database before the first meeting, then use the meeting to test what the filings leave out. In my experience the questions that separate providers are operational: who can authorize a transfer, what happens when the adviser leaves, and what your records look like a decade later.
Part of our guide: Family Office.
The short version
- A registered adviser owes you a brochure, and a Form CRS if you are a retail investor. Both are already public, so read them before you take the meeting (17 CFR 275.204-3).
- The crypto-specific competence is operational. Ask who can authorize a transfer and what the second control is, because that is where the expensive failures live.
- Get the scope in writing, naming the work that falls outside it and who performs that instead. Undefined edges are where tax, custody, and estate work drop.
- An adviser’s retention obligation runs five years from the fiscal year of the last entry, which is a compliance floor and a poor archive (17 CFR 275.204-2(e)(1)).
- No category of provider is a proxy for competence here. Run identical checks on every firm on the list.
Start with the filings
Two documents exist before you make contact, both required by rule. First, the brochure:
“If you are registered under the Act as an investment adviser, you must deliver a brochure and one or more brochure supplements to each client or prospective client that contains all information required by Part 2 of Form ADV”
Second, the relationship summary, which a registered adviser “must deliver … to each retail investor” (17 CFR 275.204-5(a)). If you assume that term excludes you, the rule defines a retail investor as a natural person receiving services “primarily for personal, family or household purposes.” Account size does not move you out of it.
Both sit on the SEC’s Investment Adviser Public Disclosure system, and broker-dealer records on BrokerCheck. The SEC is blunt about why:
“Unlicensed, unregistered persons commit much of the investment fraud in the United States.”
Reading them first changes what the meeting is for. You arrive knowing the disciplinary history, the outside business activities, the affiliations, and the stated fees, so the hour goes on what the brochure covers only in general language and what it never reaches, which for digital assets is most of the operational surface.
You are also owed a brochure supplement for the individual who will actually advise you, delivered before that person begins, and where more than five supervised persons work the account only the five with the most significant day-to-day responsibility need one (17 CFR 275.204-3(b)(3)). Ask which ones you should be receiving.
The questions that separate providers
Firms sound alike about markets and diverge sharply on operations. A firm can be strong at portfolio construction while holding no worked-out position on any of the following, and size, age, ownership, and business model tell you none of the answers. The same five questions apply to a bank trust department, a brokerage firm, an independent registered adviser, an accounting firm, and a family office group.
Authorization. Who can initiate a movement of your assets, what approval that takes, and whether anything you sign at onboarding lets the firm act without a fresh instruction. This one is checkable rather than a matter of trust. The books and records rule already requires a registered adviser to keep “a list or other record of all accounts in which the investment adviser is vested with any discretionary power” over client funds or securities, and “all powers of attorney and other evidences of the granting of any discretionary authority by any client” (17 CFR 275.204-2(a)(8) and (a)(9)). Ask how your account would appear on that list, while you can still decline.
Custody. Whether the firm will have custody in the regulatory sense, which pulls in a separate rule about where client assets are held (17 CFR 275.206(4)-2), and if so, with which custodian and under what account title. The custody hub covers the arrangements; for selection, the signal is that the answer comes back immediate and specific.
Failure and departure. What happens if the named adviser leaves, the firm is acquired, or the registration ends. Ask for three separate answers: your access to the assets, the custody arrangement, and your records. Firms that have worked this through answer in operational detail.
Records. What arrives, in what format, on what schedule, and whether reported balances are reconciled against the chain. Note the floor the rule sets: required records are kept “in an easily accessible place for a period of not less than five years from the end of the fiscal year during which the last entry was made” (17 CFR 275.204-2(e)(1)). Basis questions on a long-held position routinely arrive after that window closes, so keep independent copies from day one. Common crypto tax record mistakes covers what the file has to hold.
Conflicts and disclosure. Ask what the firm receives from anyone other than you: custodians, platforms, product sponsors, referral sources. If a third party recommended the firm and was compensated for it, the marketing rule requires clear and prominent disclosure that “cash or non-cash compensation was provided,” plus “the material terms of any compensation arrangement” (17 CFR 275.206(4)-1(b)(1)). If you never saw that, ask why. How firms charge is compared model by model in fee-only crypto financial advisor, and fiduciary status and its verification method in what is a crypto fiduciary advisor.
Get the scope in writing
The engagement is the only document that binds, and it is where a good conversation either survives or evaporates. Write down what the firm is engaged to do, then the work sitting outside it and who performs that instead: who prepares the tax reporting, who updates estate documents, who holds keys, who reconciles wallet-level records, and who confirms assets actually moved when a plan says they should.
Two terms are worth settling at signing: what you receive on termination, meaning which records in what format within how many days, and what notice applies if the individual advising you changes. Both cost nothing in advance and turn into arguments later.
What I actually see
The comparison gets run on the wrong axis. Someone meets three firms, hears three versions of the same reasonable market view, and chooses on rapport, because nothing in those conversations produced an answer that differed between them. The operational questions do produce different answers, which is what makes them useful for choosing.
The filings go unread until something has already gone wrong. I have watched people discover an affiliation or a disciplinary disclosure a year into a relationship, sitting in a document that was public, free, and filed before their first phone call.
Nobody names the client’s remaining job. The firm takes on advice and reporting for the assets it can see, the client assumes that covers everything, and a self-custodied wallet that never came up goes unrecorded for years. It surfaces at tax time or at death, by which point the reconstruction is forensic.
The check I would run. Write out, in order, the exact sequence that would have to occur for one position to leave your holdings and arrive somewhere else: who initiates, who approves, what the second control is, where the firm sits at each step, and what changes if your contact is unreachable for a month. Send it to every firm on the list, ask each to correct it in writing, then read the corrected versions side by side. The spread will be wider than anything you heard about strategy, and unlike a strategy discussion it is verifiable.
Where this goes wrong
The choice gets made on rapport and reputation, and the operational questions get deferred until they are decisions somebody else already made.
The specific failures: discretionary authority granted at onboarding and never described to the client in plain language, so nobody can state afterward what was authorized. An engagement with no written boundary, so custody and tax records belong to nobody. A compensated referral whose disclosure nobody read. Statements reporting positions never reconciled against on-chain balances, so an error rides along through years of filings. An acquisition where the relationship transfers and the working files do not. And a basis history the adviser was never engaged to produce and the CPA assumed existed, discovered the spring after a large sale.
The decision rule
- Pull the filings before the first call. Search the firm and the individual on IAPD and BrokerCheck, and read the brochure and Form CRS end to end.
- List every disclosure you found, disciplinary or otherwise, and raise each one in the meeting instead of after signing.
- Write the transfer sequence and require each firm to correct it in writing, including who authorizes and what the second control is.
- Ask what happens on departure, separately for asset access, custody, and records, and get the answer into the engagement.
- Settle custody as its own decision, confirming which entity holds the assets, under what account title, and who reconciles reported balances.
- Define your record package: what arrives, in what format, how often, and keep independent copies instead of relying on any firm’s retention period.
- Put the scope in writing, naming the work outside it and the professional who owns that work.
- Ask what the firm receives from third parties, and require the answer in the engagement rather than the brochure alone.
Where this sits
Selection is one decision inside a larger set. What crypto wealth management covers defines what you are buying, fiduciary status is a separate check with its own method, and how firms are paid has its own comparison. Custody sits underneath all of it, concentration is often the reason someone is hiring at all, and a trustee running this search for a trust carries an additional duty layer.
These questions cross professional boundaries, and the join is where things fail. The attorney drafting your documents, the CPA filing your returns, and whoever holds the keys rarely see each other’s work, so gaps open where their engagements stop: an authorization that exists operationally and nowhere on paper, a basis record each of them assumed the others kept. Selection is the moment you can assign that join to a named person, and most engagement letters never mention it.
Sources
- 17 CFR 275.204-3, Delivery of brochures and brochure supplements (Cornell LII)
- 17 CFR 275.204-5, Delivery of Form CRS (Cornell LII)
- 17 CFR 275.204-2, Books and records to be maintained by investment advisers (Cornell LII)
- 17 CFR 275.206(4)-1, Investment adviser marketing (Cornell LII)
- 17 CFR 275.206(4)-2, Custody of funds or securities of clients by investment advisers (Cornell LII)
- SEC, Check Out Your Investment Professional (Investor.gov)
- SEC, Investment Adviser Public Disclosure
Related
- What is crypto wealth management?
- What is a crypto fiduciary advisor?
- Fee-only crypto financial advisor
- Can a trustee hire a crypto advisor?
- How do I protect crypto wealth?
- Crypto wealth management
Last updated: 3 August 2026.
This article is general education, not legal, tax, or investment advice. It does not recommend any firm, adviser, or category of provider, and careful selection can reduce certain risks but does not eliminate them. Talk to a qualified attorney or CPA about your own situation.
