Every step from entity formation to your first annual amendment — 72 items across 10 phases for advisers registering with the SEC or a state securities division.
SEC vs. state jurisdiction test before you file anything
IARD / CRD account setup, entitlement forms, and funding
Form ADV Parts 1A, 2A, 2B, and Form CRS drafting order
Day-one policies, contracts, and books & records setup
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What's inside
10 phases, 72 line items — sequenced in the order you actually have to complete them, with the dependencies that trip up first-time registrants flagged inline.
1
Phase 1 — Jurisdiction: SEC, state, or exempt reporting adviser
2
Phase 2 — Entity formation, EIN, banking, and ownership records
3
Phase 3 — IARD / CRD entitlement, account funding, and fee math
4
Phase 4 — Form ADV Part 1A item-by-item preparation
5
Phase 5 — Part 2A brochure and Part 2B supplements
6
Phase 6 — Form CRS (Relationship Summary) for retail firms
7
Phase 7 — Required policies: compliance manual, code of ethics, BCP, Reg S-P, AML
8
Phase 8 — Client agreements, fee schedules, and solicitor arrangements
9
Phase 9 — IAR licensing, exams/waivers, and state notice filings
10
Phase 10 — Day-one operations and the first-year deadline calendar
Decide your jurisdiction before you draft a single form
Filing in the wrong place is the most expensive mistake a new adviser makes, because the fix means withdrawing and re-filing. Registration is driven by regulatory assets under management, the type of clients you serve, and how many states you have a place of business in.
In broad terms: advisers with less than $100 million in regulatory AUM generally register with the states where they have a place of business or exceed a de minimis client count, advisers at or above $100 million (or $110 million for initial SEC registration) register with the SEC, and private fund advisers may qualify as exempt reporting advisers that file only an abbreviated Form ADV. Advisers required to register in 15 or more states may elect SEC registration instead.
Compute regulatory AUM using the Form ADV Part 1A Item 5.F instructions, not your internal billing number
Identify every place of business — a home office in a second state counts
Check each state's de minimis client threshold and its notice-filing rules
Confirm whether any affiliate registration (broker-dealer, CTA/CPO, insurance) applies
Set up IARD before your filing deadline, not after
You cannot submit Form ADV without an entitled IARD account and a funded Flex-Funding account. Entitlement paperwork, super-account-administrator designation, and funding by check or wire each take business days, and a shortfall in the Flex-Funding account silently blocks submission.
Budget for the initial IARD system fee, the SEC or state registration fee, IAR licensing fees per person per state, and any state notice-filing fees. Our state filing fee database keeps the current per-state amounts.
Submit the FINRA entitlement forms and designate a super account administrator
Fund the Flex-Funding account for filing plus IAR fees with a buffer
Create user accounts for anyone who will draft or submit filings
Draft the disclosure documents in dependency order
Part 1A is the regulatory data set, Part 2A is the plain-English brochure, Part 2B covers supervised persons who provide advice, and Form CRS is the two-page relationship summary required of firms serving retail investors. Drafting them out of order produces contradictions that examiners find immediately.
The fee, conflicts, custody, and discretion answers in Part 1A must match Part 2A word-for-word in substance, and your client agreement must match both. That three-way alignment is a standing exam question for new registrants.
Reconcile fee schedules across Part 1A Item 5, Part 2A Item 5, and the advisory agreement
Disclose every conflict you actually have, including affiliate revenue and outside business activities
Prepare Part 2B for each supervised person who formulates or delivers advice
File Form CRS on the same schedule as Part 2 if you have any retail investor clients
The policies that must exist on day one
A registered adviser is expected to have a written compliance program adopted before it takes on clients — not drafted after the first exam notice. At minimum that means a compliance manual keyed to your actual business, a code of ethics with personal trading reporting, a business continuity and succession plan, a privacy program under Regulation S-P, and cybersecurity and vendor oversight procedures.
SEC-registered advisers and, effective January 1, 2028, advisers subject to FinCEN's AML/CFT rule also need an anti-money-laundering program with independent testing. Firms serving retail clients should have a Reg BI-aware supervisory approach where dual registration applies.
Compliance manual mapped to Rule 206(4)-7 and your services
Code of ethics, access person list, and initial/annual holdings reports
Business continuity, succession, and key-person coverage
Reg S-P privacy notice, safeguards, and incident response
AML/CFT program and independent testing schedule where applicable
Marketing and advertising review procedures under Rule 206(4)-1
Your first twelve months of deadlines
Registration approval is the start of a recurring calendar. The annual Form ADV amendment is due within 90 days of fiscal year end, IARD renewals run through the fourth quarter, the annual compliance program review under Rule 206(4)-7 must be documented, and state notice filings renew on their own schedules.
The checklist closes with a month-by-month first-year calendar you can drop straight into your compliance calendar, cross-referenced to our 2026 compliance deadline calendar.
Built by working CCOs
Drawn from registration engagements across SEC, state, and exempt-reporting advisers.
Sequenced, not just listed
Phases run in the order the filings actually depend on each other.
2026-current
Includes FinCEN AML timing, Marketing Rule, and Reg S-P amendments.
Frequently asked questions
How long does investment adviser registration take?
Plan on 45 to 90 days from entity formation to approval. State reviews often involve one or two rounds of comments; SEC applications are typically declared effective within 45 days of a complete filing. Drafting the brochure and compliance manual is usually the longest step, not the regulator's review.
Do I register with the SEC or my state?
It depends on regulatory assets under management, client type, and where you have places of business. Advisers under $100 million in regulatory AUM generally register with states, advisers at or above the $110 million initial threshold register with the SEC, and private fund advisers may qualify as exempt reporting advisers. Our free registration calculator routes your specific facts.
What does it cost to register a new advisory firm?
Beyond legal and consulting help, budget for the IARD system fee, the SEC or state registration fee, per-state IAR licensing fees, notice-filing fees, and exam or waiver costs. Fee amounts vary by state — the checklist links to our state filing fee database for current amounts.
Can I use this checklist for a broker-dealer or fund manager?
The core phases apply to any new registrant, and the checklist flags which items differ for broker-dealers (Form BD, FINRA new member application, FINOP and principal registrations) and for private fund managers (Form D, Blue Sky notice filings, fund documents).
Registering a new firm this year?
FIN Group runs RIA, broker-dealer, and fund registrations end to end — filings, disclosure documents, policies, and the first annual review.