# How to Start an RIA: SEC vs State Registration

As of Oct 20, 2026, an adviser with $100 million or more in assets under management generally registers with the SEC and a smaller adviser generally registers with its state, and the SEC's IARD fee schedule lists an initial filing fee of $40, $150 or $225 depending on assets.

As of: 2026-10-20
Address: https://advisoriq.com/practice/guides/how-to-start-an-ria-sec-vs-state-registration/

## Facts

- Summary: The assets thresholds that decide SEC or state registration, the exceptions, and the filing steps from IARD access to state notice filings.
- Key facts: A state-regulated adviser generally cannot register with the SEC unless it has at least $25 million in assets under management or advises a registered fund; advisers between $25 million and $100 million that must register with, and be examined by, their home state generally may not register with the SEC.; An adviser may, but need not, register with the SEC at $100 million to under $110 million, and need not withdraw until assets fall below $90 million.; The SEC must grant registration or institute proceedings within 45 days of the application.; A state may not require registration of an adviser with no place of business in the state and fewer than 6 clients who live there in the preceding 12 months.

## Notes

- Educational, not legal, tax or investment advice.
- Practice management content is not eligible for CFP Board CE. CFP Board plans to allow up to five hours of it per cycle once its Q4 2027 changes take effect.

## Sources

- Legal Information Institute, Cornell Law School: 15 U.S.C. 80b-3a (Investment Advisers Act Section 203A), state and Federal responsibilities, checked 2026-10-20: https://www.law.cornell.edu/uscode/text/15/80b-3a
- Legal Information Institute, Cornell Law School: 17 CFR 275.203A-1, eligibility for SEC registration; switching to or from SEC registration, checked 2026-10-20: https://www.law.cornell.edu/cfr/text/17/275.203A-1
- Legal Information Institute, Cornell Law School: 15 U.S.C. 80b-3 (Investment Advisers Act Section 203), registration of investment advisers, checked 2026-10-20: https://www.law.cornell.edu/uscode/text/15/80b-3
- Legal Information Institute, Cornell Law School: 15 U.S.C. 80b-18a (Investment Advisers Act Section 222), State regulation of investment advisers, checked 2026-10-20: https://www.law.cornell.edu/uscode/text/15/80b-18a
- Legal Information Institute, Cornell Law School: 17 CFR 275.203A-2, exemptions from the prohibition on SEC registration, checked 2026-10-20: https://www.law.cornell.edu/cfr/text/17/275.203A-2
- Legal Information Institute, Cornell Law School: 17 CFR 275.203A-3, definitions (investment adviser representative, place of business), checked 2026-10-20: https://www.law.cornell.edu/cfr/text/17/275.203A-3
- NASAA: Exam FAQs (Series 65 and Series 66), checked 2026-10-20: https://www.nasaa.org/exams/exam-faqs/
- U.S. Securities and Exchange Commission, Division of Examinations: Risk Alert: Observations from Examinations of Newly-Registered Advisers, checked 2026-10-20: https://www.sec.gov/files/risk-alert-newly-registered-ias-032723.pdf
- IARD (operated by FINRA): How to Access IARD, checked 2026-10-20: https://iard.com/how-access-iard
- U.S. Securities and Exchange Commission: Form ADV (Parts 1A, 1B, 2 and 3), checked 2026-10-20: https://www.sec.gov/files/formadv.pdf
- Legal Information Institute, Cornell Law School: 17 CFR 275.204-5, delivery of Form CRS, checked 2026-10-20: https://www.law.cornell.edu/cfr/text/17/275.204-5
- U.S. Securities and Exchange Commission: Frequently asked questions about Form ADV and IARD, checked 2026-10-20: https://www.sec.gov/about/divisions-offices/division-investment-management/electronic-filing-investment-advisers-iard/frequently-asked-questions-form-adv-iard
- NASAA: Contact Your Regulator, checked 2026-10-20: https://www.nasaa.org/contact-your-regulator/
- Legal Information Institute, Cornell Law School: 17 CFR 275.204-3, delivery of brochures and brochure supplements, checked 2026-10-20: https://www.law.cornell.edu/cfr/text/17/275.204-3
- Legal Information Institute, Cornell Law School: 17 CFR 275.204-1, amendments to Form ADV, checked 2026-10-20: https://www.law.cornell.edu/cfr/text/17/275.204-1
- Legal Information Institute, Cornell Law School: 17 CFR 275.204-2, books and records to be maintained by investment advisers, checked 2026-10-20: https://www.law.cornell.edu/cfr/text/17/275.204-2

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AdvisorIQ, as of 2026-10-20. https://advisoriq.com/practice/guides/how-to-start-an-ria-sec-vs-state-registration/

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