Feb. 27, 2026
Subject: From a small RIA Mr. Atkins, I wanted to offer some feedback on the discussion around the $100M minimum AUM for firms to be SEC Registered. I own and operate Finance Wisdom, a two Advisor State Registered RIA. I started my firm in March of 2023 after having me and my book of business sold off like a trading card. My somewhat unique clientele have me doing remote business with people all over the United States. As a result, I have been forced to register with nine different states and go through a ground up examination with each of them. Several West Coast States have all demanded different things and tried to dictate my terms of business and mandate conflicting changes to my documents. For a small startup business, I have been forced by the $100M rule to the following: Legal expenses of $35k+ Numerous revisions of documents Significant loss of my precious time Delays in getting fully registered in some states while trying to service a pre-existing client base in those same states “Spirited discussions” with several state regulators who seem to think they are the protectors of their population from an assumed evil finance guy Maybe I am unique, but I seriously doubt it. Certain (unnamed) states are making up their own rules and making it very difficult for small firms such as mine that are more likely to work with smaller clients that are ignored by the vast majority of large firms in this space. This in turn makes it more costly and difficult to be in the business at all- resulting in many Americans not having access to professional finance help (in my opinion). Bottom line, I think the $100M rule/limit should be eliminated all together or lowered significantly to maybe $20M/25M. Thank you, Jeffrey Mermilliod, MBA Financial Advisor