In providing services for assets under advisement (AUA), a firm serves as a fiduciary, with its fiduciary duties determined by whether it is acting as an investment adviser, trustee, or other type of advisor. Those services may be defined in an investment advisory agreement, trust agreement, financial services agreement, or other governing document, subject to restrictions or guidelines in an investment policy statement or similar arrangement between the firm and the owner of the assets. 

A firm’s AUA is distinct from its assets under management (AUM).  AUM are assets for which a firm is paid to provide continuous and regular investment management services with authority to use its discretion to implement transactions involving them.  

AUA and AUM services are provided by various types of firms subject to different regulatory oversight and reporting requirements, including registered investment advisers (RIAs), broker-dealers, banks, public trust companies, private trust companies, and single family offices. 

When comparing AUM or AUA for different types of firms, it is important to obtain explanations of how each firm calculates these amounts. Some firms include AUM in their calculation of AUA without making it clear they are doing so, while others report AUM and AUA separately.  To address this problem if these amounts are being evaluated, firms should be asked to explain how they calculate their AUA.  If they include their AUM in that calculation, they should be asked to report the amounts separately.