Broker-Dealer to Your Own RIA: The Full Build

Most build checklists for a new RIA are really a list of tasks with no clock on them. That is the flaw that catches people. The tasks are not the hard part — filing Form ADV, picking a custodian, wiring up a CRM are all knowable, boundable jobs. The hard part is that one of them, registration approval, runs on a clock you don't control, and it sits directly under your resignation date. Treat it as a background item and you will either resign before you are legally an adviser or push your start six weeks past when your notes said you'd be live.

So this is the build in order, with a timeline attached to each step, and one dependency called out louder than the rest. The point of sequencing it this way is to make the gating item — when your registration actually goes effective — visible from the start, because it determines the only date that matters to your income: the day you resign.

The shape of the whole build

Plan on four to six months from serious start to live, with the pure registration window — filing to effective — running roughly 30 to 90 days at the state level and up to 45 days at the SEC. The steps below overlap; entity formation, insurance, and custodian conversations run in parallel with the compliance and ADV work. But two things happen strictly in order, and both are load-bearing: your registration must be effective before you resign, and your custodian and technology must be live before you can accept a single transferred account. Everything else is choreography around those two locks.

A note on the register you're reading in. This walks the mechanics and names where a professional earns their fee. It is orientation, not legal advice — the point at which you should have securities counsel and a compliance consultant on retainer is marked plainly in the steps where it applies.

Step 1 — Form the entity

Stand up the legal entity before you file anything with a regulator, because Form ADV asks for the registrant, and the registrant is the entity, not you. Most solo and small breakaways form an LLC for the balance of liability protection and administrative simplicity; an S-corp election is a tax question to put to your accountant, not a formation question. Register in your home state, get the EIN, open the operating account.

Timeline: Week 0. Days, not weeks — an LLC filing clears in most states inside a week, faster expedited. This is the one step with no external clock, which is exactly why it should be done first and gotten out of the way.

Step 2 — Decide where you register: state or SEC

This is not a preference. Your regulatory assets under management put you in a band, and the band picks your regulator.

• Under $25M: you register with your state.
• $25M to $100M — the "mid-sized adviser" band: you generally register with the state, not the SEC. Two exceptions push you to the SEC instead: you would be required to register in 15 or more states, or your home state does not examine advisers. As of now the only current example of a non-examining state is New York. (Wyoming used to be cited here; it enacted adviser registration and no longer belongs on that list.)
• $100M and up: you are eligible for SEC registration.

Around the $100M line there is a deliberate buffer so ordinary market swings don't bounce you between regulators. You may register with the SEC once you reach $100M. You must register with the SEC once you cross $110M. And once you are SEC-registered, you need not withdraw until you fall below $90M. Eligibility is tested at your annual updating amendment, not intraday — so you are not re-checking this every time the market moves.

Why this matters for the timeline: state and SEC review clocks differ, and if you're near a threshold, which regulator you file with changes your approval window and therefore your resignation date. Settle the band before you draft ADV.

Timeline: Week 1. A determination, not a project — but a wrong call here means re-filing with a different regulator and restarting the approval clock, so make it deliberately and, if you're within a few million of a threshold, with counsel.

Step 3 — Draft and file Form ADV: Parts 1, 2A, 2B, and Part 3

Form ADV is four documents doing four different jobs, and the narrative parts take longer than people budget because they are your firm described honestly for the first time.

• Part 1 (1A/1B): the check-the-box regulatory filing submitted through IARD. It drives your registration and is what starts the regulator's review clock.
• Part 2A — the firm brochure: a plain-English narrative of your services, fee schedule, philosophy, and conflicts. Clients receive it; you update it annually and on any material change.
• Part 2B — the brochure supplement: bios and disciplinary history for the supervised people who give advice. At a solo shop, that's you.
• Part 3 — Form CRS: the two-page-maximum relationship summary for retail investors, with prescribed headings and "conversation starters," pointing clients to investor.gov/CRS. Required if you serve retail clients.

Your exam credential — Series 65, or Series 7 plus 66 — needs to be in place for anyone acting as an investment adviser representative. If your 7 is going to lapse when you leave the broker-dealer and you're going pure fee-only, confirm your IAR qualification path before it does.

This is the first place a compliance consultant clearly earns the fee. A well-drafted ADV filed complete is the single biggest thing you control to keep the approval clock from restarting — see Step 9.

Timeline: Weeks 2–6 to draft; filing ends this step and begins the approval wait. The drafting is the work; the waiting is Step 9.

Step 4 — Build the compliance program and decide who your CCO is

Under Advisers Act Rule 206(4)-7 you must adopt written policies and procedures and designate a Chief Compliance Officer. This is the role change that surprises people most: at the broker-dealer you were a supervised person and someone else owned surveillance, archiving, exams, and advertising review. Now you own all of it. The decision is who does the work.

• In-house CCO: at a small firm, salary around $120K and all-in cost often north of $150K a year. For a solo launch this usually means you wear the hat, which is legal but a real and recurring draw on the time you'd rather spend with clients.
• Outsourced CCO: a compliance firm quotes roughly $30K to $125K a year depending on your size and complexity.
• Hybrid: an outsourced firm builds and maintains the program while you hold the title and own the day-to-day — the common landing spot for a new small RIA.

Timeline: Weeks 2–8, in parallel with ADV. The written program and the ADV are the same body of work described two ways, so build them together.

Step 5 — Bind E&O and cyber coverage

Errors-and-omissions coverage for a solo runs on the order of a few thousand dollars a year on its own; bundled with cyber liability, budget roughly $5,000 to $9,000 a year for a lean solo RIA. Cyber is not optional garnish — you are now the covered institution under the privacy rules, and the same reconstruction work that rebuilds client records also concentrates a lot of personal financial data in your hands during the move.

Timeline: Weeks 6–10. Bind it before you go live; some custodians want to see coverage during onboarding.

Step 6 — Select the custodian and apply

The custodian holds client assets and is the counterparty for every transfer you're about to run, so this choice sets the texture of your operations. Minimums are real but soft, and "no minimum" is not the same promise as "same service."

• Schwab Advisor Services — no hard minimum; the largest custodian by RIA assets. Below roughly $25–50M you're on self-service tiers, with dedicated relationship management kicking in higher.
• Altruist — no minimum, built specifically for RIAs, with custody, performance, and billing consolidated in one platform.
• Fidelity — often looks for roughly $50–100M before onboarding a new RIA.
• BNY Pershing — targets larger firms, roughly a $100M practical minimum (down from higher historically).

Whichever you approach, expect due diligence on your registration status, principals' backgrounds and disclosures, projected AUM, and business model — which is why the application runs in parallel with registration, not after it. Read "no minimum" carefully: it gets you onto the platform, but the white-glove transition team that repapers accounts for you scales with expected assets. A sub-$25M solo and a $200M breakaway are both welcome at a no-minimum custodian and will get very different amounts of help moving their books.

Timeline: Weeks 4–12, overlapping registration. Start the conversation early; the account setup can't complete until your registration is effective, but the diligence and paperwork can be nearly done by then.

Where FastTrackr fits

Your custodian opens the accounts; FastTrackr fills them. The five fields you carry out are just the seed — feed FastTrackr your spreadsheets, client statements, and exports and it builds every household, member, and account, then generates the new-account paperwork pre-filled and validated. By the time the custodian is ready, the entire book is staged to open in one pass. The transfer window that usually runs months collapses to weeks.

Step 7 — Build the technology stack, in the right order

At the broker-dealer, technology was issued to you, integrated, and paid for by the firm. Independent, you select and pay for six to ten tool categories. The mistake here is not choosing the wrong single tool — it's trying to stand up all of them at once, in the weeks when your attention should be on moving clients.

Sequence it. Launch on the essentials and add the rest as you scale:

• Launch with: CRM, financial planning, and custodial connectivity. This is the minimum to onboard a client and do the work.
• Add as you scale: rebalancing, billing automation, and performance reporting/attribution. These matter, but a solo book can run for its first quarter on manual billing and the custodian's own reporting while you get the essentials solid.

Integration between tools matters more than the pedigree of any one of them. A modest CRM that talks cleanly to your planning software and custodian beats a best-in-class tool that stands alone.

Timeline: Weeks 8–14 for the launch trio; the rest across the first two quarters after you're live. Don't let "get the full stack perfect" push your resignation date — the perfect stack is a Year 1 project, not a launch prerequisite.

Step 8 — Set up billing

Configure your advisory-fee billing — tiered, flat, or AUM-percentage — tied exactly to the fee schedule you disclosed in ADV Part 2A, and set up the custodian's fee-debit authorization so fees actually pull from client accounts. Billing automation usually lives inside your portfolio-management platform, which is why it can wait a beat in the sequencing: for a small first cohort you can bill accurately by hand while the automation gets configured.

The detail that bites: advisory fees are typically drawn quarterly in arrears. An account that transfers in month two may not generate a single dollar of fee until the next billing cycle. That timing is a real driver of the Year 1 revenue trough, and it's worth modeling honestly against your runway — the arithmetic lives in the real breakeven.

Timeline: Weeks 10–14. Live before your first billing cycle after clients transfer.

Where FastTrackr fits

Clean data upstream is what makes billing and repapering just work. FastTrackr builds each household correctly once — right registrations, right assets, right fee schedule attached — so there are no billing errors to unwind and no not-in-good-order rejections sending households back to the queue. Everything downstream, from the custodian transfer to your first billing cycle, runs on the first pass.

Step 9 — Resign, then run the transfer window

Resignation comes only after your registration is effective and your custodian and technology are live. If you're moving under the Broker Protocol, you deliver a one-page resignation and a Protocol-compliant client list — name, address, phone, email, account title, and nothing else — on your way out the door. Then the accounts move.

The mechanics and the reality are two different speeds. A single account via ACATS clears in roughly six business days. The full book typically takes 60 to 120 days to substantially complete, because accounts move in waves, some assets repaper individually, and not everything transfers cleanly the first time. That window is your revenue trough, and its length is not fixed — it's a function of how ready the data was before you resigned.

Timeline: Resignation day is the pivot; the transfer window runs 60–120 days after it. The single biggest lever on that window is how much reconstruction you did before day one versus after.

The dependency that sets your resignation date

Everything above overlaps and flexes except one thing: you cannot legally operate as an adviser, and therefore cannot resign and solicit as one, until your registration is effective. This is the constraint people underestimate, and underestimating it is the most common planning failure in the whole build. It is not a background task. It is the task the calendar is built around.

The clocks:

• SEC: the SEC must act within 45 days of a complete Form ADV filing. If your filing is incomplete, staff notifies you — and a new 45-day clock starts when you resubmit. An incomplete filing does not shave a few days off; it doubles your window. This is why a clean, consultant-reviewed ADV is worth its cost.
• State: typically 30 to 90 days, varying by state.
• End to end: roughly four to six months to launch, with the pure registration piece inside that.
• The wildcard: a government shutdown can stall SEC review, and post-shutdown registration surges have produced backlogs that stretch the 45-day expectation. Current SEC processing conditions genuinely move — check them at the time you file.

The practical rule: do not put a resignation date on the calendar until your registration is effective. Advisors who set the date first, assuming approval would land on schedule, are the ones who end up in limbo — resigned or nearly so, with no effective registration to operate under. Let the approval drive the date, not the other way around.

What it costs — one-time versus recurring

Two columns, because they're two different conversations. The one-time column is what you spend to exist; the recurring column is what it costs to keep running, and it's the one that decides whether the practice pencils. A lean solo launch lands around $15,000 to $30,000 in Year 1; a fuller breakaway with staff, office, and a broader tech build runs $50,000 to $200,000.

Item	One-time	Recurring
Entity formation	Filing fee, low hundreds	State annual report, nominal
Form ADV / IARD fee (by AUM band)	$40 (<$25M) / $150 ($25–100M) / $225 ($100M+)	Annual renewal, same band
State notice-filing fees	Varies by state	Annual
Compliance program setup	~$5,000–$15,000	—
CCO — outsourced	—	~$30,000–$125,000/yr
CCO — in-house (small firm, all-in)	—	>$150,000/yr
E&O + cyber (solo)	—	~$5,000–$9,000/yr
Technology stack (CRM, planning, portfolio/billing)	Setup/onboarding varies	Scales with AUM; a few thousand up for a solo
Legal / consulting to register	~$3,000–$5,000	As needed
Custody	—	Usually no platform fee; ticket/asset charges
Lean solo launch, Year 1	~$15,000–$30,000
Fuller breakaway build, Year 1	~$50,000–$200,000

All figures move — vendor pricing, insurance premiums, and the IARD fee bands all shift, so confirm them at the time you file.

Where to go next

If you've read this far and the sequence looks manageable, the two things worth doing before you commit to a date are running the money and choosing among the routes honestly. Run your own figures through the real breakeven — the transfer window and the quarterly-in-arrears billing are the two inputs that make Year 1 tighter than the pitch admits, and both are modeled there. And if you're still weighing this full build against a lighter path, the full map of your options lays them side by side. Build the calendar around the approval clock, and the rest of the sequence holds.