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SEC / FINRA / state securities regulators

United States family office licensing requirements

Single-family, multi-family, investment office, trust, adviser, and externally marketed family office arrangements. This page maps the issue to United States application evidence, individual roles, corporate controls, public registers, and official sources.

Who this page is for

  • - Family offices
  • - Family investment companies
  • - Trust and corporate service groups
  • - Private wealth teams
  • - Registered investment advisers and exempt reporting advisers
  • - Broker-dealers and introducing brokers

Likely route questions

  • - Family office exclusion analysis under US adviser rules

Activity trigger map

  • - Whose assets are managed and who controls the office?
  • - Are services provided only to family entities or to external clients?
  • - Does the office market funds, give advice, charge fees, or accept outside capital?
  • - Which entity will manage family office assets?
  • - 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

  • - Ownership and controllers
  • - People and competence
  • - Governance and accountability
  • - Compliance framework
  • - AML/CFT and financial crime
  • - 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

  • - Assuming the phrase family office removes all licence questions.
  • - Ignoring outside capital, marketing, compensation, and advisory activity.
  • - 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.