How to Start an Advice-Only Financial Planning Firm From Scratch
No book of clients? No problem. A step-by-step guide to launching an advice-only RIA, from the Series 65 and state registration to your first paying client, with real startup costs and timelines.
Most guides to starting an RIA assume you're a breakaway advisor bringing a book of AUM clients with you. But a growing number of new firm founders look nothing like that: career changers who just earned their CFP® certification, planners leaving a broker-dealer without a portable book, or advisors at large firms who want to build something of their own without managing a single portfolio.
If that's you, here's the good news: an advice-only firm is the simplest, cheapest kind of RIA you can launch. No custodian relationship, no portfolio management software, no trading infrastructure, and in most cases no SEC registration. You're selling your planning expertise, and the business you need to build around that expertise is refreshingly small.
This guide covers the launch from zero. If you already have a practice and want to convert it, read our guide to transitioning an existing practice to advice-only instead.
First, Confirm You Actually Need to Register (You Almost Certainly Do)
A common misconception among new advice-only planners: "I don't manage money, so I'm not an investment adviser." That's wrong in nearly every state.
If you give advice about securities (which asset allocation, retirement projections, and investment recommendations all are) and you're compensated for it, you meet the definition of an investment adviser and need to register, even though you never touch client funds. RIA registration requirements apply based on what you advise on, not whether you have discretion over accounts.
The registration path is determined by assets under management. Firms with under $100 million in AUM register with their state securities regulator rather than the SEC. Since an advice-only firm manages zero assets, you will register at the state level, which is generally the simpler and cheaper path.
Step 1: Qualify With the Series 65 (or a Waiver)
Most states require investment adviser representatives to pass the Series 65 exam, which you can take without a firm sponsoring you. Many states waive the exam for advisors who hold certain designations in good standing, including the CFP® certification and the CFA charter, as noted in Kaplan's guide to starting an RIA practice.
If you already hold the CFP® marks, check your state's waiver policy before scheduling the exam. You may be able to skip it entirely.
Step 2: Form the Business and Get Insured
Before registering, set up the legal shell:
Entity formation. Most solo advice-only firms form an LLC in their home state. It's inexpensive, and the liability separation matters in an advice business.
Errors and omissions insurance. Advice-only firms still need E&O coverage. Premiums are typically modest because you carry no custody, no discretion, and no trading risk, but going without coverage is a false economy when your product is advice.
A business bank account and basic bookkeeping. Keep firm finances separate from day one. Your state auditor will eventually look at your books.
Step 3: Register Your RIA
The registration process runs through FINRA's Investment Adviser Registration Depository (IARD), where you'll file your Form ADV. According to SmartAsset's guide to starting an RIA, the full launch typically costs $10,000 to $50,000 and takes 4 to 6 months, but advice-only firms consistently land at the bottom of that range because the expensive parts (custodial setup, portfolio management systems, trading infrastructure) don't apply to you.
A few advice-only specifics for your ADV:
Describe what you actually do. Your ADV Part 2 brochure should state plainly that you provide advice for a fee, that clients implement recommendations themselves, and that you never take custody or discretion. Regulators like clarity, and so do prospective clients who read your brochure.
Fee schedule. Disclose your flat plan fees, hourly rates, and monthly ongoing fees exactly as you charge them. Percentage-of-assets language has no place in an advice-only ADV.
No custody means lighter compliance. Because you don't hold or move client money, you avoid the custody rule's surprise examination requirements entirely. Your compliance calendar still exists (annual ADV amendments, books and records, advertising review), and solo firms should follow a structured schedule like XY Planning Network's RIA compliance calendar to stay ahead of state deadlines.
If compliance feels daunting, a one-time engagement with a compliance consultant to set up your initial filings is money well spent. Many solo firms spend a few thousand dollars here and handle renewals themselves afterward.
Step 4: Design Your Service Menu and Pricing
Decide what you're selling before you register, because your ADV has to describe it. The standard advice-only menu has three tiers:
One-time comprehensive plan. Your flagship. A full analysis delivered over 2 to 4 meetings covering retirement, investments, taxes, insurance, and estate basics, with a clear implementation checklist the client executes.
Monthly ongoing. Recurring planning relationship with regular reviews and ad hoc access. This becomes your stable revenue base as the firm matures.
Hourly. A low-commitment entry point for clients with one focused question.
For pricing, start from real market data rather than guessing. Based on data from 97 advice-only planners on the Advice-Only Network (March 2026):
| Service | 25th Percentile | Median | 75th Percentile |
|---|---|---|---|
| One-time plan (n=76) | $2,000 | $3,000 | $4,500 |
| Hourly (n=75) | $250 | $300 | $360 |
| Monthly ongoing (n=48) | $199/mo | $250/mo | $399/mo |
New founders are tempted to price below the 25th percentile to win early clients. Resist the urge to go too far: underpricing attracts clients who undervalue advice, and raising fees later is harder than starting at a defensible number. Our guide to pricing advice-only services covers how to set and structure fees in depth.
Step 5: Build a Minimal Tech Stack
Your technology bill will be a fraction of a traditional RIA's because the portfolio management layer disappears. The core stack:
- Financial planning software (RightCapital, eMoney, or similar). This is your factory floor and the one tool worth paying up for.
- CRM for tracking clients and engagements.
- Scheduling, video, and e-signature tools, since most advice-only firms serve clients virtually nationwide.
- Billing that handles both one-time invoices and recurring monthly ongoing charges.
The Kitces AdvisorTech directory is the best place to compare options by category. A lean solo stack commonly runs a few hundred dollars a month. What you never need to buy: trading software, rebalancing tools, performance reporting, or a custodial integration.
Step 6: Get Your First Clients
With no book to convert, client acquisition is your real startup challenge. The founders who get traction fastest tend to do three things:
Pick a niche and write for it. Advice-only marketing is content marketing. A planner who writes specifically for, say, mid-career tech employees or federal workers will out-rank and out-convert a generalist every time. This matters doubly because the clients most drawn to advice-only are self-directed researchers; advice-only advisors are winning the next generation of clients precisely because those clients search for answers online before they search for an advisor.
Make yourself findable in directories. List your firm everywhere advice-only consumers actually look, including the Advice-Only Network directory.
Set expectations for the ramp. Most solo founders need 12 to 24 months to reach a full pipeline. Plan your personal runway accordingly, and treat every early engagement as a referral engine: delighted advice-only clients talk, because the model itself is remarkable to people who assumed all advisors take a percentage.
A Realistic Launch Budget and Timeline
Pulling it together, a typical from-scratch advice-only launch looks like:
- Months 1 to 2: Series 65 (or waiver confirmation), entity formation, E&O, service design and pricing.
- Months 2 to 4: IARD account, Form ADV drafting, state registration filing, and the waiting period while your state reviews.
- Months 3 to 5: Tech stack setup, website, directory listings, and content for your niche.
- Months 4 to 6: Approval, first engagements, and iterating your plan deliverable with real clients.
Total cash outlay commonly lands between $5,000 and $15,000 before your first revenue, well under the general RIA startup range, because the advice-only model strips out everything expensive.
The Bottom Line
Starting an advice-only firm is the rare case where the regulatory path, the cost structure, and the market trend all point the same direction. You can launch for five figures, register in one state, serve clients anywhere by video, and build recurring revenue through monthly ongoing relationships, all without the custody, trading, and conflict baggage of the AUM model.
If you're building one, don't do it alone. Join the Advice-Only Network to get listed where advice-only consumers are searching and to connect with planners who have already made the leap.