Everything to build before you file — 101 items across 10 steps covering entity formation, banking, custodian selection, technology stack, insurance, and the compliance program you need on day one.
Entity, EIN, ownership documents, and corporate housekeeping
Custodian and brokerage selection, minimums, and approval timing
The full technology stack, from CRM to archiving to billing
E&O, cyber, and bond coverage plus a realistic launch budget
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What's inside
10 steps, 101 line items — the business build that has to happen before your registration filing, in the order the dependencies actually run.
1
Step 1 — Business model, services, and fee economics
2
Step 2 — Entity formation, ownership, and corporate housekeeping
3
Step 3 — Banking, accounting, payroll, and books & records
Step 6 — Insurance: E&O, cyber, bonds, and benefits
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Step 7 — Registration readiness before you file
8
Step 8 — The compliance program to adopt before your first client
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Step 9 — Client agreements, fee schedules, and onboarding
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Step 10 — Brand, marketing, and go-live sequencing
Decide the business model before you buy anything
Most advisers start by shopping custodians and software. That is backwards. Who you serve, what you deliver, and how you are paid determine your registration path, whether you need a performance-fee analysis, which custodian will even take you, and how much technology you actually need.
Write the one-page business description first. Then work out the two-year revenue and expense model, including the months before revenue arrives. Also settle the awkward part early: what your current employer's agreements let you say, to whom, and when.
Service model and fee model, including any performance-based fees and the qualified client test
Discretionary vs. non-discretionary authority, and whether any arrangement creates custody
24-month revenue, expense, and breakeven model with a low case
Non-solicit, non-compete, garden-leave, and Protocol obligations reviewed with counsel
Entity, EIN, and banking come before the filing
You cannot register an adviser that does not exist. The IARD filing, the custodian application, and your bank all need a formed entity with an EIN, an operating agreement, and a documented ownership structure — the same ownership that appears on Form ADV Schedules A and B.
Set the fiscal year end deliberately: it sets your annual Form ADV amendment deadline for the life of the firm. And stand up the general ledger from month one, because an adviser's financial books are examinable records.
Entity type and state of formation chosen with your CPA and attorney
EIN, operating agreement or bylaws, and an ownership ledger with indirect owners identified
Registered agent, annual report, and franchise tax dates calendared
Business bank account, accounting software, chart of accounts, and a monthly close
State minimum net worth or net capital requirements confirmed where applicable
Start custodian conversations early — approval is not instant
Custodian onboarding usually takes two to six weeks, and most platforms want an approved or pending registration before they finish. Minimums matter: a platform's stated household or firm asset minimum, and what happens to your pricing and service model if you do not reach it, should be answered in writing before you sign.
Compare at least two or three platforms on minimums, technology and data feeds, alternatives access, cash sweep economics, trading workflow, and the support model for a firm your size. Document why you picked the one you picked — that is your best-execution and vendor due diligence evidence on day one.
Firm and household minimums, plus the consequence of missing asset targets
Platform, trading, and cash sweep economics compared across providers
Custodial agreement, indemnities, and data-sharing terms reviewed by counsel
Account opening, ACAT transfer, and e-signature workflow tested end to end
Written selection rationale retained in the vendor file
Build the technology stack around what you must be able to produce
The test for every tool is simple: when an examiner asks for client records, communications, trade records, or fee calculations, can you produce them completely and quickly? Technology is usually a new RIA's largest recurring cost, so buy for that test rather than for feature lists.
The commonly missed pieces are not the portfolio system — they are archiving for email, text, and social channels, a document retention scheme with access controls, tested backups, multi-factor authentication on every business system, and a written vendor inventory that shows what data each provider holds.
Portfolio management, performance reporting, and fee billing
CRM, financial planning software, and a client portal
Business email, plus text, chat, and social archiving for every channel you use
Document management with retention and version history; tested backup and restore
MFA and a password manager everywhere; written vendor list with data types and risk ratings
Insurance, compliance program, and client documents before your first client
Quote E&O and cyber coverage before you file — states and custodians often ask, and the limits affect your budget. Check the retro date and prior-acts coverage on E&O if you are leaving another firm.
The written compliance program is expected to exist before you take on a client, not after the first exam notice: a manual keyed to your actual business, a code of ethics, a Reg S-P privacy program, cybersecurity and vendor oversight, a marketing review procedure, business continuity and succession, and an AML/CFT plan for FinCEN's adviser rule effective January 1, 2028.
Finally, the economics have to agree in three places: the advisory agreement, Form ADV, and your billing system. Inconsistent fee terms are the fastest deficiency a new registrant collects.
E&O, cyber, bond, and general liability quotes with limits and renewal dates recorded
Compliance manual, code of ethics, privacy, cyber, marketing review, BCP, and AML plan
Advisory agreement and fee schedule reviewed by counsel and matched to Form ADV
Onboarding checklist covering brochure and Form CRS delivery
Annual compliance calendar with review, testing, and filing dates
A realistic timeline and budget
Plan on three to six months from decision to first client: two to four weeks for entity and banking, two to six weeks for custodian approval, three to six weeks to draft disclosure documents and the compliance program, and 45 to 90 days for state or SEC review once you file. Work streams overlap, but the drafting is almost always the long pole — not the regulator's review.
Budget beyond filing fees: technology, E&O and cyber insurance, accounting, legal review of the advisory agreement, and compliance support. State, IARD, and EDGAR fees pass through at cost, and amounts change — confirm current figures with each state.
Built for breakaways
Drawn from launches for advisers leaving wirehouses, independent broker-dealers, and existing RIAs.
Sequenced, not just listed
Steps run in the order the dependencies actually gate each other, from entity to go-live.
Pairs with the filing checklist
Hands off cleanly to our New Firm Registration Checklist when you are ready to file.
Frequently asked questions
What do I need to do before registering as an RIA?
Form the entity and get an EIN, open business banking and set up accounting, decide your services and fee model, select and get approved by a custodian, build the technology stack including archiving, obtain E&O and cyber insurance, draft your advisory agreement and fee schedule, and adopt a written compliance program. Registration is the filing at the end of that work, not the beginning.
How is this different from your New Firm Registration Checklist?
This checklist is the business build before you file: entity, banking, custodian, technology, insurance, documents, and the compliance program. The New Firm Registration Checklist is the filing itself — jurisdiction test, IARD/CRD entitlement, Form ADV Parts 1A/2A/2B, Form CRS, IAR licensing, and state notice filings. Most advisers use both, in that order.
How much does it cost to start an RIA?
Outside of legal and consulting fees, the recurring lines that matter are technology (usually the largest), E&O and cyber insurance, accounting, and archiving. One-time costs include entity formation, the IARD system fee, and the SEC or state registration and IAR licensing fees. Fees vary by state — our state filing fee database lists current amounts, and we publish flat setup pricing starting at $4,895 for a state or SEC RIA registration.
When should I talk to custodians?
Early — while your entity is being formed and before your Form ADV is drafted. Onboarding commonly takes two to six weeks and most platforms want an approved or pending registration before they complete it. Ask each platform about firm and household minimums and what happens to your pricing if you fall short.
Do I need the compliance manual before I have clients?
Yes. A registered adviser is expected to have adopted written policies and procedures reasonably designed for its actual business before it takes on clients, along with a code of ethics, a privacy program, and marketing review procedures. Drafting them after registration is a standard first-exam finding.
Planning your RIA launch?
FIN Group runs RIA launches end to end — entity and vendor setup guidance, registration filings, disclosure documents, the compliance program, and ongoing support from $295/month.