State Adviser Exams:
What NASAA’s 2025 Report
Means for RIAs
NASAA’s 2025 Coordinated Investment Adviser Exam Report is not a theoretical paper—it reflects what state examiners are actually finding in the field.
The report reviewed 1,086 investment adviser examinations conducted between February 1 and July 31, 2025, including 365 first-time adviser exams, and identified 3,402 deficiencies across 23 regulatory categories.
The most common deficiency areas continue to involve books and records, registration filings, advisory contracts, supervision and compliance procedures, and fee billing practices for state-registered RIAs. Examiners are closely reviewing whether Form ADV disclosures, client agreements, billing calculations, compliance manuals, advertising materials, and supervisory procedures are accurate, current, documented, and consistently followed.
A Practical Exam-Readiness Checklist for State-Registered RIAs
The practical takeaway is simple: do not wait for a state exam notice to fix basic compliance gaps.
For most firms, the core questions are straightforward:
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Are Form ADV Part 1 and Part 2 accurate and current?
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Are client contracts in writing and properly executed?
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Do advisory fees match the client agreement and ADV disclosures?
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Are books and records complete and organized?
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Do the website, social media, and marketing materials avoid misleading statements or missing disclosures?
Firms should proactively review Form ADV, advisory agreements, fee billing calculations, books and records, advertising disclosures, cybersecurity procedures, custody practices, senior investor policies, and the compliance manual.
Smaller investment advisers should not assume they are too small to face scrutiny. State regulators expect firms of all sizes to maintain written policies, document compliance reviews, protect client information, and implement procedures tailored to the adviser’s actual business model.
NASAA’s best practices reinforce the importance of updating client information annually, reviewing advisory contracts, maintaining written supervisory procedures, documenting fee calculations, monitoring advertising for accuracy, and keeping financial records current.
For state-registered RIAs, effective compliance does not need to be overly complicated, but it must be intentional, documented, and consistent with what the firm tells clients and regulators. A disciplined compliance review process and help firms reduce examination risk, correct deficiencies early, and demonstrate a stronger culture of compliance during state securities regulator exams.
