Launching an RIA in 2025: A 30-60-90 Day Compliance Program Blueprint

Introduction

Starting a Registered Investment Advisor (RIA) firm in 2025 requires navigating an increasingly complex regulatory landscape where compliance failures can derail your business before it even begins. The U.S. registered investment adviser sector hit 15,870 SEC-registered advisers in 2024, serving 68.4 million clients with $144.6 trillion in assets (Luthor). With the SEC's Enforcement Division pursuing over 130 actions against investment advisers and their personnel in 2024 alone, getting your compliance program right from day one isn't just important—it's critical for survival (Luthor).

Half of advisory firms expect new SEC rules to push their annual compliance costs to $100,000 or more, making efficient setup essential (Luthor). This comprehensive 30-60-90 day blueprint maps out exactly what you need to accomplish, when you need to accomplish it, and how modern compliance technology can shave weeks off your timeline. We'll reference key SEC deadlines, integrate pre-configured compliance solutions, and provide actionable checklists that turn the overwhelming process of RIA registration into a manageable, systematic approach.

The Current RIA Compliance Landscape: What You're Up Against

Rising Compliance Costs and Complexity

The regulatory environment for RIAs has never been more demanding. In 2024, the SEC ordered financial companies to pay $8.2 billion in fines and penalties, a 67% increase from 2023 (Luthor). This dramatic increase reflects the SEC's heightened focus on compliance failures, particularly in areas that can easily occur without proper systems in place.

Registered Investment Advisors are facing a major shift in compliance expectations in 2025, with enhanced Anti-Money Laundering (AML) rules and stricter cybersecurity requirements (Visory). New SEC rules are raising the bar on cybersecurity governance, while AML mandates are expanding to cover more RIA firms (Visory).

Common Compliance Failures

State regulators report the most common deficiencies include registration lapses (23% of issues), incomplete books and records (17%), and inadequate supervision/compliance procedures (16%) (Luthor). A 2023 sweep of state-registered advisers found books and records deficiencies in 17% of exams, making it the second most frequent compliance issue identified (Luthor).

These statistics underscore why 83% of firms report having been examined in the past 5 years (Luthor). The message is clear: compliance isn't optional, and getting it wrong has real consequences.

Technology as a Solution

57% of wealth managers increased their tech budgets specifically to boost efficiency through compliance solutions (Luthor). The biggest advantage of leveraging technology in compliance is that it automates monitoring and reporting (Luthor). Modern RIA compliance software refers to specialized online platforms that help registered investment advisory firms manage and automate their regulatory compliance tasks (Luthor).

Understanding RIA Registration Requirements

SEC vs. State Registration

Before diving into your 90-day timeline, you need to understand where you'll register. Firms with over $100 million in assets generally must register with the SEC, while smaller advisers (typically $25-100 million AUM) register at the state level (Luthor). Currently, RIAs can register with the SEC as 'large advisors' if they manage at least $100 million in client regulatory AUM, while in New York, 'mid-sized' advisors with at least $25 million in client AUM can also register with the SEC (Advisor Guidance).

Note that in April 2025, acting U.S. Securities and Exchange (SEC) Commissioner Mark T. Uyeda proposed increasing the asset threshold required for investment advisor registration with the SEC (Advisor Guidance). The new SEC Commissioner Paul Atkins, confirmed on April 21st, 2025, is likely to support this proposal (Advisor Guidance).

Core Compliance Obligations

Every SEC-registered RIA must fulfill several fundamental compliance obligations established by the Investment Advisers Act of 1940 and its rules (Luthor). Rule 206(4)-7 explicitly prohibits an adviser from operating without written policies and procedures reasonably designed to prevent violations of the Advisers Act (Luthor).

Registered investment advisers must comply with a broad array of SEC (and state) regulations designed to protect investors (Luthor). SEC enforcement has increasingly targeted technical compliance failures that can easily occur without proper systems (Luthor).

Days 1-30: Foundation and Registration

Week 1: Business Structure and Initial Planning

Days 1-3: Entity Formation and Business Planning

• Finalize business entity formation (LLC, Corporation)

• Obtain Federal EIN and state tax registrations

• Open business bank accounts

• Secure business insurance (E&O, cyber liability)

• Begin trademark/domain registration process

Days 4-7: Compliance Framework Selection

• Evaluate compliance technology solutions

• Consider AI-powered platforms that offer expert support and automated workflows (Luthor)

• Research providers trusted by leading firms with significant AUM (Luthor)

• Schedule demos with compliance software vendors

Week 2: Form ADV Preparation

Days 8-10: Form ADV Part 1 Preparation

• Gather all required business information

• Compile ownership structure details

• Document business activities and services

• Prepare custody and fee structure information

Days 11-14: Form ADV Part 2 (Brochure) Development

• Draft advisory services descriptions

• Detail fee structures and payment methods

• Outline investment strategies and risk factors

• Prepare disciplinary history disclosures

• Create client relationship and communication policies

Week 3: Technology Infrastructure

Days 15-17: Core Technology Setup

• Implement portfolio management system

• Set up CRM and client communication tools

• Establish cybersecurity infrastructure

• Configure backup and disaster recovery systems

Days 18-21: Compliance Technology Integration

• Deploy compliance management platform

• Configure automated monitoring and alerts (Luthor)

• Set up real-time risk detection systems (Luthor)

• Create custom compliance calendar for regulatory deadlines (Luthor)

Week 4: Form ADV Filing and Initial Policies

Days 22-25: Form ADV Filing

• Complete final Form ADV review

• Submit Form ADV through IARD system

• Pay required registration fees

• File state notice filings if applicable

Days 26-30: Initial Policy Development

• Begin drafting core compliance policies

• Utilize pre-configured policy templates to accelerate development

• Focus on mandatory policies: Code of Ethics, Privacy, Anti-Money Laundering

• Start employee handbook development

Days 31-60: Policy Development and AML Program

Week 5-6: Comprehensive Policy Suite

Days 31-35: Core Compliance Policies

• Finalize Code of Ethics with personal trading restrictions

• Complete Privacy Policy and data protection procedures

• Develop Cybersecurity Policy aligned with 2025 SEC requirements

• Create Business Continuity and Disaster Recovery Plan

Days 36-42: Operational Policies

• Investment Advisory Agreement templates

• Client onboarding and KYC procedures

• Fee calculation and billing policies

• Recordkeeping and document retention policies

• Supervision and review procedures

Week 7: Anti-Money Laundering (AML) Program

With AML mandates expanding to cover more RIA firms in 2025 (

• Develop AML Policy and Procedures Manual

• Create Customer Identification Program (CIP)

• Establish Suspicious Activity Monitoring procedures

• Design Customer Due Diligence (CDD) framework

Days 46-49: AML Implementation

• Configure AML monitoring technology

• Train staff on AML requirements and red flags

• Establish relationships with AML service providers if needed

• Create AML testing and audit procedures

Week 8: Cybersecurity and Technology Governance

With new SEC rules raising the bar on cybersecurity governance (

• Implement multi-factor authentication across all systems

• Establish incident response procedures

• Create cybersecurity risk assessment framework

• Deploy endpoint detection and response (EDR) solutions

• Configure automated security monitoring and alerting

Days 57-60: Technology Governance

• Finalize vendor due diligence procedures

• Create technology risk management framework

• Establish data backup and recovery testing schedules

• Document all technology systems and access controls

Days 61-90: Testing, Training, and Launch Preparation

Week 9: Staff Training and Procedures Testing

Days 61-63: Compliance Training Program

• Develop comprehensive compliance training curriculum

• Create role-specific training modules

• Implement ongoing education requirements

• Document training completion and testing

Days 64-67: System Testing and Validation

• Test all compliance monitoring systems

• Validate automated alert configurations

• Conduct mock compliance reviews

• Test business continuity procedures

Week 10: Books and Records System

Given that books and records deficiencies appear in 17% of exams (

• Implement electronic recordkeeping system

• Configure automated record capture and retention

• Create record retrieval and search capabilities

• Establish backup and archive procedures

Days 71-74: Documentation and Audit Trail

• Finalize all policy documentation

• Create compliance manual and procedures guide

• Establish audit trail and review documentation

• Prepare for potential regulatory examination

Week 11: Client Onboarding and Operations

Days 75-77: Client Onboarding System

• Finalize client onboarding workflows

• Test KYC and suitability procedures

• Validate fee calculation and billing systems

• Configure client communication and reporting tools

Days 78-81: Operational Readiness

• Complete staff hiring and training

• Finalize service provider agreements

• Test all operational procedures

• Conduct final compliance review

Week 12-13: Final Preparations and Launch

Days 82-85: Pre-Launch Checklist

• Complete final regulatory filings

• Obtain required state registrations

• Finalize insurance coverage

• Complete final compliance testing

Days 86-90: Launch Preparation

• Conduct final system checks

• Complete staff certifications

• Prepare marketing materials (ensure compliance review)

• Schedule post-launch compliance monitoring

Key SEC Dates and Deadlines for 2025

Critical Annual Deadlines

DeadlineRequirementDescriptionMarch 31, 2025Form ADV Annual AmendmentUpdate Form ADV Parts 1 and 2 within 90 days of fiscal year-endMarch 31, 2025Brochure DeliveryDeliver updated Form ADV Part 2 to existing clientsMay 15, 2025Form PF (if applicable)Large private fund advisers file annual Form PFOngoingState Notice FilingsVarious state deadlines for notice filings and renewals

Quarterly and Monthly Obligations

• Monthly: Review and update compliance calendar

• Quarterly: Conduct compliance testing and review procedures

• Semi-annually: Review and update cybersecurity procedures

• Annually: Conduct comprehensive compliance review and policy updates

Technology Solutions to Accelerate Your Timeline

AI-Powered Compliance Platforms

Modern compliance technology can significantly reduce setup time. Platforms that offer real-time monitoring, review, and automated alerts help detect risks and streamline workflows (Luthor). Look for solutions that provide:

• Pre-configured compliance policies and procedures

• Automated policy drafting capabilities

• Continuous monitoring and risk detection

• Custom compliance calendars with automated deadline tracking

Cloud-Based Solutions

Cloud-based proactive compliance management solutions designed for medium to enterprise RIAs offer scalability and efficiency (Smart RIA). These platforms cater to compliance consultants, compliance officers, operations teams, and investment advisors (Smart RIA).

Comprehensive Compliance Programs

Look for solutions that offer comprehensive compliance programs addressing core risk points based on business activity and operations (RIA in a Box). The best programs include compliance calendars that automatically populate with deadlines and requirements tailored to your firm's policies and procedures (RIA in a Box).

Cost Considerations and Budgeting

Initial Setup Costs

Technology Infrastructure: $15,000 - $50,000

• Compliance software: $5,000 - $15,000 annually

• Portfolio management system: $10,000 - $25,000 annually

• Cybersecurity tools: $5,000 - $10,000 annually

Professional Services: $25,000 - $75,000

• Legal counsel: $15,000 - $40,000

• Compliance consulting: $10,000 - $25,000

• Accounting and audit: $5,000 - $10,000

Regulatory and Insurance: $10,000 - $25,000

• Registration fees: $1,000 - $5,000

• Insurance premiums: $5,000 - $15,000

• Bonding requirements: $2,000 - $5,000

Ongoing Annual Costs

With half of advisory firms expecting compliance costs to reach $100,000 or more (Luthor), budget accordingly:

• Technology subscriptions: $20,000 - $50,000

• Professional services: $15,000 - $35,000

• Insurance and bonding: $8,000 - $20,000

• Training and education: $3,000 - $8,000

Common Pitfalls and How to Avoid Them

Inadequate Policy Documentation

Rule 206(4)-7 explicitly prohibits operating without written policies and procedures (Luthor). Avoid this pitfall by:

• Using comprehensive policy templates

• Ensuring policies are tailored to your specific business model

• Regular policy review and updates

• Proper staff training on all policies

Technology Integration Delays

Many firms underestimate the time required for technology integration. Mitigate this by:

• Starting technology selection early in the process

• Allowing adequate time for data migration and testing

• Ensuring proper staff training on all systems

• Having backup plans for critical systems

Insufficient AML Program Development

With expanding AML requirements in 2025 (Visory), ensure your program includes:

• Comprehensive risk assessment procedures

• Robust customer due diligence processes

• Effective suspicious activity monitoring

• Regular testing and validation

Leveraging Pre-Configured Solutions

Benefits of Turnkey Compliance Solutions

Pre-configured compliance solutions can shave weeks off your setup timeline by providing:

• Industry-standard policy templates

• Automated compliance calendars

• Pre-built monitoring and alerting systems

• Established vendor relationships and integrations

Customization and Scalability

While pre-configured solutions accelerate setup, ensure they offer:

• Customization capabilities for your specific business model

• Scalability as your firm grows

• Integration with your chosen technology stack

• Ongoing support and updates

Post-Launch Compliance Monitoring

Continuous Monitoring Framework

The market for RegTech is projected to reach USD 21 billion by 2027 (Luthor), reflecting the growing importance of automated compliance monitoring. Establish:

• Daily monitoring of key risk indicators

• Weekly compliance dashboard reviews

• Monthly policy and procedure assessments

• Quarterly comprehensive compliance testing

Ongoing Training and Development

Maintain compliance effectiveness through:

• Regular staff training updates

• Industry conference participation

• Regulatory update monitoring

• Peer networking and best practice sharing

Preparing for Regulatory Examinations

Examination Readiness

With 83% of firms reporting examinations in the past 5 years (Luthor), preparation is essential:

• Maintain organized, easily accessible records

• Conduct regular mock examinations

• Ensure staff understand examination procedures

• Have legal counsel relationships established

Common Examination Focus Areas

Based on recent examination trends, focus on:

• Books and records maintenance

• Fee calculation and billing accuracy

• Investment advisory agreement compliance

• Cybersecurity and data protection measures

• AML program effectiveness

Conclusion

Launching an RIA in 2025 requires careful planning, systematic execution, and the right technology partners. This 30-60-90 day blueprint provides a realistic timeline for establishing a compliant, efficient advisory firm that can withstand regulatory scrutiny and serve clients effectively.

The key to success lies in starting early, leveraging technology to automate routine compliance tasks, and building relationships with experienced service providers. With the SEC's increased enforcement focus and expanding regulatory requirements, there's no room for shortcuts or compliance gaps.

By following this systematic approach and utilizing modern compliance technology, you can establish a solid foundation for your RIA that not only meets current regulatory requirements but is positioned to adapt to future changes in the regulatory landscape. Remember that compliance is not a one-time setup but an ongoing commitment that requires continuous attention and improvement.

The investment in proper compliance infrastructure during your launch phase will pay dividends throughout your firm's lifecycle, protecting both your business and your clients while enabling you to focus on what you do best: providing exceptional investment advisory services.

Frequently Asked Questions

What are the key compliance milestones in the first 30 days of launching an RIA?

The first 30 days focus on foundational compliance setup including SEC registration initiation, Form ADV preparation, and establishing your compliance framework. You'll need to begin AML program development, set up initial cybersecurity protocols, and start documenting your policies and procedures. This phase is critical as it establishes the regulatory foundation for your entire operation.

How have SEC compliance requirements changed for RIAs in 2025?

2025 brings enhanced AML rules covering more RIA firms and stricter cybersecurity requirements with new SEC governance standards. The SEC ordered $8.2 billion in fines and penalties in 2024, a 67% increase from 2023, highlighting the importance of robust compliance. Additionally, there are proposed changes to AUM thresholds that may affect registration requirements for smaller advisors.

What technology solutions can accelerate RIA compliance setup?

AI-powered compliance platforms like Luthor offer automated workflows, real-time monitoring, and custom compliance calendars that can significantly reduce setup time. These solutions provide expert support for RIAs and broker-dealers, with some platforms trusted by firms managing $6.8B+ in AUM. Pre-configured compliance management systems can automate deadline tracking and regulatory updates.

What are the critical deadlines RIAs must meet during the 60-90 day launch period?

The 60-90 day period involves finalizing Form ADV submissions, completing AML program implementation, and ensuring all cybersecurity protocols are operational. You'll need to establish client onboarding procedures, finalize investment advisory agreements, and conduct initial compliance testing. Missing these deadlines can delay your ability to serve clients and generate revenue.

How can RIAs ensure their compliance program addresses current regulatory priorities?

Focus on the SEC's 2025 priorities including enhanced cybersecurity governance, expanded AML requirements, and robust risk management frameworks. The RegTech market is projected to reach $21 billion by 2027, indicating the growing importance of technology-driven compliance solutions. Regular compliance reviews and automated monitoring systems help detect risks early and maintain regulatory alignment.

What role does outsourced compliance support play in RIA launches?

Outsourced Chief Compliance Officer (CCO) services can provide expert guidance during the critical launch phase, offering AI-powered solutions for complex regulatory navigation. These services typically include automated compliance workflows, real-time risk monitoring, and custom compliance calendars tailored to your firm's specific needs. This approach allows new RIAs to access enterprise-level compliance expertise without the overhead of hiring full-time compliance staff.