Who Is a “Control Person” at an RIA?
Control isn’t limited to majority owners — someone with a smaller ownership stake but significant influence over firm decisions, or an officer with broad authority, can also qualify as a control person. The SEC’s threshold guidance generally treats 25% or greater ownership as presumptive control, but the actual test looks at real decision-making power, not just equity percentage.
Accurate control person disclosure matters for transparency around who actually runs the firm, and it feeds into other obligations, including background disclosure requirements for those individuals.