RIA Registration FAQs

Have a business entity established with your state.
- XYPN will not advise on business entity formation
- If you choose to proceed with registration using a pre-existing entity, our timeline estimates will not be accurate. You are opening yourself up to increased scrutiny from your state. We do recommend that your RIA be a completely separate business entity.
Establish a business bank account
Know if you are using your home address as the business address and, if not, have an alternative ready.
Know if you are using your email address and, if not, have an alternative ready.
Know what services you want to offer
- Financial planning? Investment Management? Both?
Know what fees you want to charge
- You should enter into the process with a range of fees for each service
- Are you basing your fees on complexity, AUM, etc.?
Know what a wrap fee is and if you want to incorporate one
Decide if you want discretionary authority
Have a clear transition plan or timeline for departing from your current employer.

Taking advantage of all XYPN compliance resources (Office Hours, the forums, and XYPN Academy). Almost all questions have been answered before and will be answered more quickly in these ways than through email.
We use Google Docs to draft your ADV; get comfortable editing or updating the Google Doc drafts yourself!
- Don’t be afraid of messing things up. The Compliance Team can always see your edits and correct them as needed.
Not requesting significant changes to your fees or services after the ADV has been filed
Not asking the Compliance team members to provide business planning (not compliance) advice and or recommendations.
Reaching out to your regulator to discuss your “special circumstances", if needed.
- CRD record disclosures or wildly unorthodox fees/services/etc. That the compliance team is not able to advise upon.
Forwarding the compliance team communication from the regulators during registration (Send it all! Even if it looks like we have been copied.)
- Related: Always let the Compliance Team know if you’ve communicated directly with the regulator or visited the regulator’s office.
Realizing that the Compliance Team has many other registrations occurring simultaneously and not everyone will receive an email from their compliance associate every day with an update.
Turn existing websites (including LinkedIn or other social media) private until your registration is complete to avoid additional questions and scrutiny from the regulator.

Advisors will be responsible for mailing hard-copy documents as their state requires. The Compliance team will submit documents electronically and advise you on what to mail and where to send them. You will need to send the hard copies to your state.

There are two types of CRD numbers: Personal and Firm.
- You receive a firm CRD number when you create a FINRA account. That is your firm’s CRD.
- You may have been given a personal CRD number depending on previous employment (specifically in the financial industry). That would be your CRD number. If you do not have a personal one, one will be created during the ADV drafting process!
- These are tied to your social security number, which is used perpetually.

Yes - you need one physical address to list on your ADV. You can use your home address as your physical address if you don’t want to get an office space, but keep in mind this will be listed on publicly available documents.
- You can note “by appointment only” as hours of business
- Virtual offices can be acceptable, but virtual mailboxes are not (one that opens and scans mail) is NOT accepted.
- Please keep in mind where you would meet with your auditor. Where would your books and records remain? If you have multiple addresses, we’ll want to list all addresses.

It doesn’t matter if it’s personal or business - the most important thing is NOT to change it during the process. Whatever email you use to make your account in FINRA should be the same email listed on your ADV. Otherwise, it will be noted as a deficiency and slow down the approval process.

Default to "by appointment only" unless you are consistently at the office for the same time every day.

Instead of passing on fees from the custodian and broker (brokerage commissions, transaction fees, etc.) to the client, you would be paying the costs yourself, and the client’s payment to you for your Investment Advisory services will be inclusive of all transaction-based fees. Not all custodians can facilitate through a wrap rep code, so you must confirm with your custodian before beginning a wrap fee program. If you decide to participate in a wrap fee program, we will also need to add a Wrap Fee Brochure to your ADV filing, and we can also assist you with that.

The client can authorize you to have the custodian pull advisory fees instead of having them write a check. This is the most common payment method for Investment Management Services.
This is only applicable to those using Investment Management Services.

They are your business formation documents (although they may have different names depending on the type of business).
80% of the time, states need copies of these documents.
This is NOT something XYPN supports, reviews, or drafts from a legal perspective. Please reach out to LegalZoom.com or a similar service for assistance.
Members should have these documents drafted before beginning the registration process.

Keep it simple! You can always add services later. When you have services fleshed out, you can always add an amendment.

% of assets under management, hourly fees, flat fees, and monthly/quarterly retainer fees?

You most likely will need to produce a balance sheet and an operating agreement to your state during the compliance process. Your state may also require that you meet minimum net capital requirements for your business (May include personal net capital/net worth if Sole Prop).
If you’re concerned about preparing your balance sheet or other financials, we recommend you reach out to Bean Counters, and they will be happy to assist you!

Have a question not on this list? Please attend Registration Drop-In Office Hours, weekly on Wednesdays 9:30 - 10:30am MST.