To start your RIA in New Hampshire, you must meet specific state requirements. Here we will list what those are.
Advisors that meet the following criteria will register their RIA with the state: actively practice in the state and manage less than $100 million in AUM, manage assets for more than 5 New Hampshire residents, or solicit their financial services in the state.
Consider hiring a compliance consultant to help set up an RIA in New Hampshire. A compliance consultant will help ensure that all your paperwork is filed correctly.
New Hampshire requires that advisors have one of the following professional designations: Series 65, Series 7 & 66, CFP, CFA, CIC, ChFC, or PFS.
In addition to paying all the registration and filing fees, IARs must complete the following tasks and submissions with the state:
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Submit FINRA Entitlement Paperwork
To register your RIA, your must first apply for an account to FINRA’s WebCRD/IARD online system. Through FINRA’s site, you will submit your registered investment advisor application. FINRA doesn’t regulate or supervise RIAs–it’s just used by the state to process applications. -
Form ADV Part 1 (online only)
This is the online portion of your application, where you will disclose the following RIA information: Ownership, clients, business practices, disciplinary events related to the advisor or its employees, and any affiliations. Form ADV Part 1 serves as the vehicle to upload ADV Part 2A and ADV Part 2B. -
Form ADV Part 2A (paper and online)
This serves as the Firm’s Disclosure Brochure and features information about the RIA’s fees, services, disciplinary disclosures, and other information related to the firm. New Hampshire requires this to be given to prospective and current clients and be written in plain, understandable English. -
Form ADV Part 2B (paper and online)
Information about the advisor is listed in this brochure (advisors must give this to clients), including their education, employment history, potential conflicts of interest, and any disciplinary actions. Additionally, any Executive Officers or representatives who advise clients must complete this form.
If sponsoring a wrap fee program, Appendix 1 is also required. -
Form U4
This registers your firm’s Investment Advisor Representatives (IARs).
Financial statements and other documents:
Custody of client assets requires an audited financial statement. If there's no custody, financial statements that are certified by the investment advisor must be submitted.
If you’re seeking approval as a state RIA for the first time, you must complete the following:
- E-billing establishment & processing
- SAA Creation & FINRA Entitlement
- IARD/CRD Access & Authentication
Beyond financial statements, New Hampshire may require the following documents:
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Client Advisory Contract
The state requires this filing to ensure that the RIA meets the regulatory standards for client advisory contracts. -
Privacy Policy Statement
This statement is given to all clients at the start of the working relationship and every year thereafter. The RIA must share how they handle, store, and disclose client information. While the statement will be unique to every RIA, it must still meet the state of New Hampshire’s compliance requirements. -
Policies and Procedures Manual
The Policies and Procedures manual is an internal guide for RIAs to adhere to processes and procedures. The manual must have information from how the RIA handles client complaints to how it trains new IARs. It must also have guidance on Business Continuity, Anti-Money Laundering, Information Security, and Anti-Insider Trading plans. -
Code of Ethics
RIAs must meet specific fiduciary standards set forth by the state of New Hampshire, and this filling will confirm that.
Starting an RIA doesn’t have to be overwhelming with the right resources, such as our comprehensive RIA launch kit.
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To see how we’re helping RIAs streamline operations, reduce overhead, and elevate the client experience, book a call with one of our transitional specialists now.
*Altruist and its affiliates do not provide legal advice, so it’s important to check with a qualified professional for each state’s registration requirements.
