NASAA Model Rule

NASAA Registration Rule

The NASAA Model Rule on Registration establishes the framework for investment adviser registration at the state level, including initial registration requirements, qualification examinations, renewal procedures, and ongoing reporting obligations for state-registered firms.

Key Requirements

Initial Registration Filing

Investment advisors must file Form ADV (Parts 1 and 2) through the IARD system and submit the required state registration fee before conducting advisory business in the state.

Qualification Examinations

Principal officers and investment adviser representatives must pass the Series 65 (Uniform Investment Adviser Law Examination) or hold equivalent qualifications such as certain professional designations.

Net Worth and Bonding Requirements

States may require minimum net worth levels or surety bonds, particularly for advisors with custody or discretion over client assets.

Annual Renewal

Registrations must be renewed annually through IARD by December 31, including payment of renewal fees and filing of any required updates.

Form ADV Amendments

Material changes to the information on Form ADV must be filed promptly (typically within 30 days), and annual updating amendments are due within 90 days of fiscal year-end.

State Adoption Status

All 51 jurisdictions — universal requirement for state-registered IAs and IARs

Adoption of NASAA model rules varies by state. Some states adopt the model rule directly, while others have their own rules covering the same requirements.

Visit the State Adoption Tracker for a complete per-state breakdown. Data sourced from NASAA model rule matrix and NV 2024 Legislative Survey. Last verified March 2026.

Common Violations

Avoid these frequently cited deficiencies during state examinations.

Late Registration Renewals

Missing the annual renewal deadline, resulting in lapsed registrations and potential unauthorized advisory activity.

Outdated Form ADV

Failing to file timely amendments when material changes occur, such as changes in ownership, disciplinary events, or business operations.

Unregistered Representatives

Allowing investment adviser representatives to conduct advisory business before their state registrations are approved.

Multi-State Registration Gaps

Conducting advisory business in states where the firm or its representatives are not properly registered.

Best Practices

Set up calendar reminders 60 days before annual renewal deadlines
Conduct quarterly reviews of Form ADV for accuracy and completeness
Maintain a centralized tracking system for all representative registrations across states
Implement a process to verify registration status before representatives engage clients in new states
Review net worth and bonding requirements annually as the firm grows
Keep detailed records of all qualification examinations and professional designations

Frequently Asked Questions

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