Who this page is for
- - Startup fund managers
- - Private fund advisers
- - Managed account platforms
- - Family office spin-outs
- - Registered investment advisers and exempt reporting advisers
- - Broker-dealers and introducing brokers
Likely route questions
- - SEC or state investment adviser registration; exempt reporting adviser analysis for private funds
Activity trigger map
- - Who has discretion over portfolio decisions?
- - Are investors in a fund, separate account, managed account, or platform product?
- - Does the manager also market funds, give advice, or place trades?
- - Which entity will manage investment portfolios or funds?
- - How will professional, accredited, institutional, or wholesale client status be evidenced and monitored?
- - Which domestic permissions, representative approvals, and ongoing obligations apply before launch?
Individual requirements
- - Investment adviser representatives may require state registration depending on facts
- - Broker-dealer registered representatives require firm sponsorship, CRD filing, exams, and registration
- - Chief compliance officer and supervised person controls are central for adviser models
- - Supervision and qualification exams matter for FINRA member firms
Corporate requirements
- - Form ADV, disclosure brochure, compliance program, custody analysis, books and records, and annual amendments for advisers
- - FINRA New Member Application, supervisory procedures, personnel, systems, capital, and membership standards for broker-dealers
- - State notice filing or registration analysis where applicable
- - Clear separation between advice, brokerage, solicitation, custody, and fund management activities
People and key-person expectations
- - Investment adviser representatives may require state registration depending on facts
- - Broker-dealer registered representatives require firm sponsorship, CRD filing, exams, and registration
- - Chief compliance officer and supervised person controls are central for adviser models
- - Named owners should be able to explain the activity workflow, client type, controls, and evidence pack.
Documents and evidence checklist
- - People and competence
- - Governance and accountability
- - Capital and financial resources
- - Compliance framework
- - Custody and client assets
- - Financial forecasts
- - Official-source route memo
- - Public register verification plan
- - Questions log for qualified advisers
Capital, timeline and bottlenecks
Adviser capital rules are usually state-specific or tied to custody and other facts; broker-dealers face SEC net capital and FINRA membership expectations.
Timeline estimate: SEC adviser registration can become effective in about 45 days if complete; FINRA new member review may run up to 180 calendar days for substantially complete applications.
- - Broker-dealer issues hidden inside compensation, solicitation, placement, or transaction workflows
- - Custody, private fund audit, and fee deduction arrangements not fully analysed
- - Form ADV and brochure language that does not match real operations
- - FINRA NMA materials that are not substantially complete or lack operational evidence
Common mistakes
- - Treating asset management as a single global licence label.
- - Ignoring dealing, advice, marketing, and custody steps around the mandate.
- - Investment adviser and broker-dealer are not interchangeable labels.
- - State registration can matter even when the commercial plan feels national.
Disclaimer
Information on LicenseCompare is for general educational purposes only and does not constitute legal, regulatory, financial, tax, investment, or professional advice. Licensing requirements depend on facts and change over time. Always consult official regulator materials and qualified professional advisers.