RIA Registration Questionnaire Guide
Completing your RIA Registration Questionnaire is an important step toward getting your firm registered and ready to launch. This guide walks you through each section of the questionnaire, highlighting what information you’ll need, offering helpful context, and sharing expert insights along the way.
Use this guide as a companion as you work through the questionnaire, and don’t worry if you’re unsure about an answer. Your Registration Specialist will review your responses and help make sure your registration documents accurately reflect your firm.
Tell Us About Your Firm
This section provides us with essential details about your firm.
Firm’s Full Legal Name
- Enter your legal business name exactly as it appears on your formation documents (e.g., including “LLC” or “Inc.”), or your full legal name if operating as a sole proprietor.
- Expert Insight: We can begin drafting your application documents even if you haven't officially registered your entity with the Secretary of State.
Firm's Primary Business Name
- The client-facing name used throughout your compliance documents (advisors often drop "LLC" or "Inc." here).
- Expert Insight: If this differs from your legal name, you may need to file a trade name or "doing business as" (DBA) registration with your state.
Entity Type
- This is the type of entity that you have created with your Secretary of State. We most commonly see LLCs, but we do occasionally see corporations and sole proprietorships.
- Expert Insight: We can proceed with the drafting of your application documents even if you have not created your legal entity with your Secretary of State. If you are unsure of what type of entity to form, we recommend consulting with a legal professional or accountant to help determine the best structure for your business.
Firm’s Contact Info
- Phone Number
- This phone number will be used by our team or a regulator to contact you.
- You may use your personal phone number if you don't have a business phone number. If needed, we can update this number after the firm's approval by filing an other-than-annual ADV amendment.
- Principal Place of Business
- This is where you will perform your advisory services, and must be a physical location. Please indicate if this address is your home address.
- Mailing Address
- We will also need your mailing address if it is different from your principal place of business address.
- Expert Insight: We'll add your website and social media to firm documents once your firm has been approved. Until that point, you’ll want to keep your website 'under construction' or 'private' to avoid any unnecessary scrutiny from the state regulator.
Ownership
- All owners of the firm need to be disclosed in the ADV.
Registration Information
This section lets us know how and where the firm will need to be registered, as well as how many people need to be registered as Investment Adviser Representatives of the firm.
State vs. SEC Registration
- Most advisors we work with are state-registered. In order to qualify for SEC Registration, you must meet at least one of the following requirements;
- The firm reasonably expects to have over $100 million in AUM within 120 days of launch
- The firm is required to register with the securities authority of at least 15 different states
- The firm has over $25 million in AUM and is principally located in the state of New York
Registering in Additional States
- If you expect that the firm will take on any clients in states other than your home state, you may want to consider beginning the registration process there as a part of your initial registration.
- Please consult this blog article to see if an additional state registration would be right for your firm.
- The registration timeline varies greatly by state. Please consult your assigned Registration Specialist about timelines for each state.
Client Referrals
- Disclose details if you plan to pay compensation for client referrals, as some referral arrangements require those individuals to register as IARs. Your Registration Specialist will review your state's specific solicitor rules.
Investment Adviser Representatives
- If the firm has any employees that need to become registered as Investment Advisor Representatives (IARs) of the firm besides yourself, please report this here. Information about additional IARs will be collected at the end of the questionnaire.
Firm Services
In this brief section of the questionnaire, you will identify the types of clients the firm will serve and the services that you will offer them.
Client Types
- You’ll want to select all of the types of clients your firm will provide advisory services to. The client types you see listed align with ADV Part 1. If you have a client type that you don’t see specified, please include them in the “Other” section.
- Expert Insight - at a minimum, you’ll likely be working with Individuals and High Net Worth Individuals
Firm Services
- Please select all of the services that the firm will offer to clients within the first six months of launching. The ADV is a living document, so it should be accurate at all times. If a service is listed in the ADV, then your firm needs to be prepared to offer it.
Investment Management
Types of Investment Management Services
- If you are planning to utilize an Outside Manager/TAMP/Sub-Advisor, we may request a copy of the sample agreement to confirm that the billing procedures listed in the ADV are correct. We’ll also need to know who pays the Outside Manager/TAMP/Sub-Advisor; will this fee be passed on to the client, or will your firm absorb the fee?
- Unsure if your service qualifies as a TAMP? Check out these resources to learn more about them:
Trading Authority
- Discretionary Authority provides the advisor with trading authorization, and the Advisor is free to buy and sell securities without consulting the client before effecting a transaction.
- Non-Discretionary Authority still provides the advisor with trading authority. However, the Advisor must consult with the client and obtain approval before effecting the transaction.
- Check out this blog article on the differences between discretionary and non-discretionary authority
Custody
- If you plan to have custody of client assets, including third-party SLOAs, we’ll include the required disclosures in the ADV.
- Not sure if SLOAs will apply to your firm? Check out this resource in XYPN Academy!
Wrap Fee Program
- A Wrap Fee Program is a bundled fee structure where clients pay a single, all-inclusive fee that covers investment advice, portfolio management, trading costs, custodial fees, and administrative expenses. If you’d like to offer a Wrap Fee Program, we’ll draft a Wrap Fee Brochure for you after ADV Part 2A/2B is finalized.
- Expert insight: A Wrap Fee Program used to be common for new independent firms, but as major custodians now offer zero-commission trading on standard stocks and ETFs, wrap fees have become unnecessary in most cases because there are no transaction fees to be bundled.
- Have questions about Wrap Programs? Check out this blog article!
Block Trading
- Answer Yes if you plan to group multiple client trades together to buy or sell a security in a single transaction. Answer No if you plan to trade each client's account individually.
Written Reports
- These are optional, custom performance reports (separate from mandatory custodian statements and firm invoices). Answer Yes only if you want to commit to sending them; if listed in your ADV, you are legally required to send them and maintain strict delivery logs.
Ongoing Financial Planning
A subscription-based model for long-term financial planning engagements.
Fee Structure
- Regulators closely scrutinize ongoing fees. To justify them, we implement a client service calendar to outline exactly what value you deliver every billing period.
- Creating Client Service Calendars That Demonstrate Ongoing Advisor Value
- Michael Hartman’s Client Service Calendar And One-Page Financial Snapshot
- We also have service calendar templates available for download on Academy.
- Expert Insight: We recommend providing a range for all fixed fees to allow for the most flexibility.
Project-Based/Hourly Financial Planning
These are typically one-time financial planning engagements with a limited scope.
Fee Structure
- Expert Insight: For hourly fees, however, regulators prefer to see one flat hourly rate rather than a range.
Educational Seminar & Speaking Engagements
Only list this service and your billing structure if you plan to charge a fee for these events. Free seminars do not need to be disclosed as a firm service.
Retirement Plan Consulting | 3(21) Fiduciary
A 3(21) fiduciary is an investment advisor who provides advice to Plan sponsors on investment strategies, investment options, and plan design. This service is only applicable if an employer or Plan sponsor will be your client.
Expert Insight: We recommend reading this Kitces article to determine if this service is right for your firm.
Retirement Plan Management | 3(38) Fiduciary
A 3(38) fiduciary is an investment advisor who has the discretionary authority to manage the Plan's assets, including making investment decisions. This service is only applicable if an employer or plan sponsor will be your client.
Expert Insight: We recommend reading this Kitces article to determine if this service is right for your firm.
Investment Analysis, Strategies, Risks, and Securities
This section asks about additional details about your firm’s business practices. Your firm’s practices around providing investment advice need to be disclosed in the Form ADV, so you’ll want to select all of the options that are applicable to your firm. If an option not listed is relevant to your firm, please provide a brief description in the “Other” section.
Even though we ask that you list the types of securities the firm will advise on, you can still provide advice on a client's legacy portfolio that includes a security not listed on the ADV. This section only pertains to the securities that your firm will work with regularly.
Non-Advisory Activities of the Firm
Non-Advisory activities of the firm are services done under the firm’s name and business that do not constitute advisory activity in the same way as Financial Planning or Investment Management. This may include a service such as online financial coaching.
An online coaching service would not typically fall under “advisory services” because of their focus on education and exclusion of personalized investment advice. Therefore, you do not need advisory contracts for attendees, and the ADV delivery requirements should not apply.
Tax Preparation
Because tax prep does not inherently involve giving investment advice, it is a Non-Advisory activity. Tax prep can be offered in several different ways that make it a nuanced service to disclose. If your firm offers tax preparation, we ask that this section be filled out so that we can determine how to disclose this service properly. If you’re having trouble answering all of these questions, just do your best! Your Registration Specialist will review the details with you in your Pre-Registration Onboarding Call.
CCO Information
Up until this point, the questionnaire has been all about your firm. Now we get to learn about you!
Name
- Enter your first and last name exactly as you want it to appear on your legal and compliance documents.
Title(s)
- As the business owner, you will automatically serve as the firm’s Chief Compliance Officer (CCO). Let us know if you would like to include additional titles on your documents, such as CEO, Owner, or Founder.
Professional Designations
- In your ADV Part 2B, we’ll list any professional designations that you currently hold. If you have obtained a professional designation that is not specifically listed, let us know and we’ll be sure to include it.
Insurance License
- Let us know if you hold an active insurance license, as it must be disclosed in the ADV.
- Fee-Only Reminder: As an XYPN member, you must operate strictly on a fee-only basis (all compensation comes exclusively from client fees; no commissions or insurance product payouts are permitted)
Personal CRD Number
- Provide your CRD number if you have one, and we will pull your employment history directly from your public profile. If you do not have one, we will create it for you.
Employment History
- The ADV requires your full 5-year employment history, and the Form U4 requires your full 10-year employment history; the history cannot have any gaps longer than 3 months.
- If you do not have a CRD number, list your history from most recent to oldest, excluding your new firm. Report any gaps by listing the employer as "self-employed" and your title as "unemployed," "retired," or "sabbatical".
- If you do have a CRD number from a prior registration, we will collect your employment history from your most recent U4 filing; we can fill in any gaps in employment since your last U4 filing as a part of the ADV review process.
Education History
- ADV Part 2B requires your post-high school formal educational history. Please list your degrees and schools from most recent to oldest.
Outside Business Activities
- Do you plan to have any outside business activities (OBAs) after your firm is approved? If so, we’ll need to know:
- The name of the OBA
- Your position and duties
- The percentage of your time it takes during trading hours
- Whether or not it is investment-related
- Expert Insight: How do I know if my OBA requires disclosure? We’ll need to disclose an OBA that fits any of the following criteria:
- Takes up 10% or more of your time
- Contributes to 10% or more of your income
- Is industry or investment-related
Additional IAR Information
For each additional IAR that needs to be registered with the firm, we will need to collect the same information that we did for you as the CCO. Every IAR gets an ADV Part 2B!
Additional Information
This is where you can share any additional details you’d like our team to know, as well as upload any attachments you may have.
Congrats! You made it to the end of the RIA Registration Questionnaire! Once you click “submit,” we will receive a copy of the form that your Registration Specialist will review before your Pre-Registration Onboarding Call to get to know a little about you and your firm. After that, the questionnaire will serve as the basis for how your firm’s documents get drafted and tailored to your business.