The RIA Registration 
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A guide to registering your RIA with State and SEC Regulators
Move Forward with Confidence
An Introduction to Your RIA Registration Journey
Thank you for taking the time to learn about Advisor Guidance’s hands-on approach to helping you register your investment advisory firm.
Whether you need to register your RIA at the state level or with the SEC, this guide offers a clear roadmap to prepare you for everything you need to know about registering your RIA firm.
In addition to providing you with a clear path forward, this guide also details how our registration and compliance team will manage this process for you every step of the way.
If at any time you have a question about starting a new firm, or a compliance related question, please drop us a line.
RIA Registration Handbook Table Of Contents
Where Do I Register My Firm?
State Registration
SEC Registration
In addition to the SEC’s exemption for firms expecting to have $100M or more in regulatory AUM within 120 days of registering, a firm may also register with the SEC if the firm is an Internet-only advisory, or the firm is required to register in 15 or more states.
The Major Difference Between State vs. SEC Registration
The process of preparing and submitting the application is almost the same for both state and SEC firms. The big difference, however, is that the SEC generally doesn’t require additional documents beyond Form ADV, Form CRS, and Form U4 submission through the FINRA Firm Gateway. We will touch on the other differences later in this guide.
Before Registering Your RIA Firm
4 Things You Need to Know & Do
Before you start the formal registration of your RIA firm, you should take the time to ensure you have a solid foundation to launch your firm. As part of the pre-registration process, we strongly encourage you to address each of the items below.
If you have already addressed these items, please proceed to the Your Path to Approval section.
✔ Check Your Current Employment Agreement
If you’re transitioning from a broker-dealer or other RIA firm and plan to invite your clients to come with you—or you’re thinking about telling them that you might start your own firm, we strongly encourage you to check your employment contract first.
Many firms now include non-compete, non-solicit, or non-accept clauses (collectively, ‘NCAs’) in their employment agreements to protect their corporate assets. While you may think the clients are “yours,” they technically are clients of the firm. For this reason, it is essential to review your agreement for these stipulations prior to communicating with any clients.
If you’re not clear on what you can and can’t do, seek legal advice.
Is Your Contract Binding?
Check out this blog post to learn about The Broker Protocol & the 3 types of non-competes.
✔ Make Sure You Have the Proper Industry Credentials
To register your RIA and qualify as an investment adviser representative (IAR), you must meet specific examination requirements. This primarily involves passing the Series 65 exam requirement.
If you haven’t previously passed the Series 65 exam or if you have passed the Series 65 but haven’t held an active IAR registration within the last 24 months, you’ll need to meet one of the following three options to proceed with your registration:
- Take and pass the Series 65 exam (investment adviser law examination)
- Possess, and have in good standing, one of the following professional designations
- Certified Financial Planner (CFP)
- Chartered Financial Analyst (CFA)
- Chartered Investment Counselor (CIC)
- Chartered Financial Consultant (ChFC)
- Personal Finance Specialist (PFS)
- Hold an active Series 7, Series 66, and Securities Industry Essentials (SIE) examination
- If you are currently or were recently registered with a Broker-Dealer (BD) or Hybrid BD/RIA within the last 24 months, the SIE and Series 7/66 combination may be relevant for you. In some states, individuals with substantial and recent securities industry experience may be eligible for an exam waiver. These states have specific written request procedures and our compliance team is available to assist you in navigating them.
✔ Name Your Firm
Establishing your brand identity is a critical step in launching and growing a successful RIA firm. Developing a solid name for your firm is often the first step in this process. However, it can be difficult to land on a name that best represents the key characteristics of your business.
Before registering your firm, you should take some time to think through the naming process and vet the name you plan to use to ensure it is not already trademarked by another firm. There are plenty of online tools you can use to run your name search.The U.S. Small Business Administration offers some great resources you can use to get started.
✔ Set Up Your Legal Entity
While the majority of startup RIAs we work with are Limited Liability Companies, we suggest that you consider the tax implications of each entity before setting up the legal structure of your RIA firm.
There are several entities to choose from, each of which has pros and cons that you should first discuss with your legal counsel:
- Sole Proprietorship – Essentially, you individually are the firm. This arrangement is best suited for a solo practice with limited risk and where you are willing to accept personal liability for any errors.
- Partnership – Generally set up with two or more individuals who each contribute something to the business. There may be several limited partners, or one general partner and other limited partners. Profits and losses are distributed to the partners pro rata, in accordance with their partnership interests.
- Corporation – Whether you call it a C-Corp or an S-Corp, a corporation is owned and can be managed by its shareholders. This structure offers maximum legal liability protection to its shareholders. However, corporate tax liability at the company level and individual income tax liability at the shareholder level should be considered (i.e., the company is taxed on revenue, and shareholders are taxed on dividends and capital gains).
- Limited Liability Company – The “best of both worlds” that is a combination of a partnership and corporation. Members are protected from legal liability, while profits and losses are distributed pro rata and without corporate tax.
Watch Our Founder John Shields Give a Fundamental Overview on the RIA Registration Requirements.
Our Turnkey Registration Approach is Your Easiest Path to Approval.
Since 2006, our proven registration process has helped thousands of advisors launch their firms with confidence. The best part? We do 97% of the work for you!
"The staff at Advisor Guidance thoughtfully guided me through every step of the process required to become a fiduciary. In short, they understand the nuances of the advisory business in a way that few others do. I couldn’t have done it without him, in fact I wouldn’t even have come close!. "
What’s Your 3%?
During the initial set up and kickoff call, you’ll be responsible for helping us set up your login accounts with FINRA and answering questions about your firm. Depending on whether you’ll be applying for state or SEC registration, you may also need to provide us with a copy of your corporate formation documents and a financial statement. This is your 3 per cent. Once we have this information, our registration and compliance team will manage the entire process for youl. It really doesn’t get much easier than that.
Step 1 RIA Firm Preparation
As the first step in our registration process, your dedicated registration lead will send you our new firm questionnaire and walk you through the process of accessing the FINRA Firm Gateway.
The FINRA Firm Gateway is the regulatory filing and reporting portal used to administer your registrations and filings for your firm and all supervised representatives.
You will use the New Organization SAA Entitlement Form to set yourself up as the Super Account Administrator (SAA). Once established, our compliance team will coach you on how to set up specific entitlements so they can access the Firm Gateway and draft and file your registration when the time is right.
In addition to helping set up your SAA account, our compliance team will instruct you on how to fund your FINRA “E-Bill” account. E-Bill is FINRA’s financial system that enables users to view and fund all the accounting details of FINRA Flex-Funding and Renewal Accounts, pay annual renewal assessments, and view and pay FINRA invoices.
It is imperative to pay these fees and ensure they are available in your E-Bill account so the Form ADV can be submitted to initiate your firm’s registration.
To start your registration, your dedicated registration lead will:
- Send you our new firm questionnaire for you to complete
- Guide you through the set up of the FINRA Entitlement process
- Instruct you on how to fund your FINRA “E-Bill” account
Navigating the FINRA Firm Gateway
Within the FINRA Firm Gateway, you will have access to both the Central Registration Depository (CRD) and the Investment Adviser Registration Depository (IARD) system.
The CRD System is your primary dashboard when logged in and is where we administer the registration and filing information for any IAR of your firm.
The IARD System is where your firm’s Form ADV is filed, including filing for your firm’s registration with any jurisdiction.
AG Fact
The Advisor Guidance team has helped RIA firms get registered in every state in the U.S. and Puerto Rico.
Step 2 RIA Registration Kickoff Call
Our Kickoff call is where you pass our compliance team the baton and they take the lead. But before they start running full speed, they’ll need a clear understanding of how you plan to operate your firm.
An average registration kickoff call with our compliance team typically takes 60 to 90 minutes depending on the complexity of your business.
During this conversation, our compliance team will review your completed new firm questionnaire and take a deeper dive into key elements of your RIA, including your business model, fee structure, and custodian selection.
They will also discuss any initial compliance concerns and provide insight into designing a customized compliance program that will suit your business model.
The goal of this call is to equip our team with the insights needed to draft and file your ADV, and to give you the support and clarity you need to launch your firm with confidence. This is a great opportunity to ask them specific questions about how to operate your firm.
Looking to Maximize Your Free Time?
Now that our compliance team is leading the registration process for you, we’d encourage you to check out our Ultimate Checklist for Starting an RIA to make sure setting your firm up for success.
Step 3 ADV Drafting & Filing
Once we have access to your FINRA Firm Gateway, your E-Bill Account is fully funded,, and you’ve completed our Kickoff Call, you can take a deep breath. This is when our team takes the lead and starts crafting the most important document in the RIA registration process: the Form ADV.
The Form ADV
If you’re unfamiliar with the specifics of the Form ADV, it’s basically a standardized filing that provides detailed information about an RIA’s services, fees, business practices, and any conflicts of interest you or the firm may have with clients. It consists of four parts, which are itemized as Part 1, Part 2A, Part 2B, and Part 3.
Form ADV Overview
- ADV Part 1 collects detailed, structured information about the investment adviser’s business, including ownership, client base, number of employees, business practices, affiliations, and any disciplinary history of the firm or its employees. This section is primarily for regulatory use and is submitted through the IARD system.
- ADV Part 2A (also known as the “Firm Brochure,” and if applicable, the “Wrap Fee Program Brochure” or “Part 2A Appendix 1”)
Part 2A is a narrative brochure provided to clients that outlines key information about your firm—its services, fee structure, disciplinary history, conflicts of interest, and key personnel. It must address 18 required disclosure items (19 for state-registered firms) and is a core component of your public-facing compliance documentation. - ADV Part 2B (also known as the “Brochure Supplement”)
Part 2B provides background information on the individual advisers at your firm who provide investment advice. It includes details such as their education, business experience, any disciplinary history, and other business activities, and should align with the information disclosed on each individual’s Form U4. - ADV Part 3 Customer Relationship Summary (Form CRS)
Also referred to as the “Customer Relationship Summary,” the Form CRS is a two-page, plain-language disclosure document designed to help retail investors make informed decisions when choosing an advisory firm. It provides a broad overview of your services, fees, conflicts of interest, and regulatory obligations, as well as background information about your firm. The goal is to promote transparency and ensure clients understand how your firm aligns with their goals and needs.
NOTE
Form CRS currently only applies to investment advisers registering with the SEC and state-registered advisers applying for registration with Rhode Island.
The Importance of the Form ADV
Your Form ADV, particularly Part 2A, is commonly known as your firm’s disclosure brochure—or simply, your “firm brochure.” This document is a key component of your registration application and plays a critical role during the review process. State regulators (or the SEC) will focus heavily on the content of your firm brochure when evaluating your application.
Form ADV Considerations
It’s common for new advisers to feel uncertain about what to include in their firm brochure, especially knowing their business may evolve after launch. We always remind our clients that this document isn’t meant to be permanent. The firm brochure is a living disclosure that can—and should—be updated as your services, fee structure, and business practices develop over time. Other than the initial registration filing fee and the annual registration renewal fee, there is no fee required to file an amendment to Form ADV.
When drafting your Form ADV, our compliance team focuses on your firm’s services, compensation model, and business practices you plan to implement within your first year of operation. Your firm brochure doesn’t need to capture every future possibility—just what you are reasonably certain about.
As your firm grows and requires Form ADV updates, we offer flexible, ongoing compliance support and will be here to assist you.
NOTE
Once you review, approve and permit us to file your registration with the appropriate regulators, the official review process will begin.
Step 4 Form U4 Drafting & Submission
In addition to drafting and filing your firm’s ADV, our compliance team will also prepare the necessary Form U4s for each investment adviser representative (IAR) at your firm.
The Form U4 (Uniform Application for Securities Industry Registration or Transfer) is required by the state securities regulatory agencies to gather employment history and background information. IARs are not regulated only by their home state securities regulator and by the state securities regulators in any state where the IAR seeks additional registration.
Important Note for Breakaway Advisors:
Breaking away from your current firm may need to be handled with the utmost secrecy. Some broker-dealers and RIAs will terminate your employment immediately if they discover you are planning to depart. If you are planning to start a new firm or join an existing firm without your current employer knowing, please let us know during our kickoff call. There are ways we can help file applications confidentially.
Step 5 Crafting Your Customized Compliance Program
Once we’ve filed your Form ADV and the appropriate Form U4s, our team will craft a customized compliance program for your RIA. As part of this process, we will draft your firm’s written policies and procedure manual, which includes your firm’s Code of Ethics, Written Supervisory Procedures (WSPs), Business Continuity Plan, Cyber Security Policy, and Privacy Policy. We have various other policy and procedure documents depending on your business model and regulatory agency. For example, we can draft a Proxy Voting Policy and Procedures, and we also can draft state-specific policies and procedures (e.g., Massachusetts Personal Information Policy, Missouri Data Backups and Restoration, and applicable vulnerable adult procedures).
In addition to providing all of the documents you need to satisfy the compliance and regulatory requirements outlined under the Investment Advisers Act of 1940 (for SEC-registered firms) or state statutes rules and regulations (for state-registered firms), our team will also provide you with the Investment Advisory client contracts for your various securities-based services.
Your Advisory Client Agreements
Most jurisdictions require written agreements to be in place for every advisory client. These agreements, in addition to other required contract provisions, must include:
- Description of services to be provided
- Term of the contract
- Applicable planning and/or advisory fee
- Formula for computing the fee if it is anything other than a flat/fixed fee
- Amount of any prepaid fee (if applicable) to be returned in the event of termination
- Any grant of discretionary trading authority to the investment adviser
Your Review and Approval
Step 6 Regulatory Review & Response
After we’ve filed the Form ADV and the Form U4 for each IAR of the firm through the IARD and CRD systems of the FINRA Gateway, we will submit all of the additionally required compliance documents to the appropriate regulator(s). As mentioned earlier in Where Do I Register My Firm? State vs. SEC Registration, the SEC generally only needs to see the Form ADV Parts 1, 2, and 3, whereas each state has its own additional document filing requirements other than Form ADV Parts 1 and 2.
Once the state or SEC receives all required information, the application is placed in a queue for examiner review.
This review process at the state securities agency level can vary significantly from state to state. For example, some states assign an examiner to immediately review the application, while others place the application in a queue for review in order of date received. This review period is when the regulators will correspond with us to address any questions or ask for specific changes based on their interpretation of your disclosure documents and the adequacy of any additional documents submitted. This correspondence comes in the form of a deficiency notice.
After we review the examiner’s questions and comments, our team will draft and review our responses with you to ensure they align with your business model. Once approved by you, we will then submit them to the examiner. In most cases, our response to the deficiencies will initiate the approval process. Some states send just one deficiency notice, while others send multiple notices.
Step 7 Registration Approval
After we’ve submitted your application, the approval process can range from a few weeks up to six months depending on the regulatory agency.
The SEC usually approves investment adviser applications within 30-45 days, assuming all information is correct and there are no compliance or ownership issues. However, state registrations usually take longer and approval times can vary from as soon as three weeks to up to six months.
As your partner in this process, our Compliance Team will actively monitor your application status and address any communications you receive from the regulators. We’ll keep you informed and celebrate when your firm gets approved.
Once your firm is approved, you can begin to onboard clients, launch your firm’s website, and start delivering financial guidance on your terms.