Most advisors complete RIA registration in 30 to 90 days. Here is what each phase involves, what causes delays, and how to keep your filing on track.


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| Regulator | New Mexico Regulation and Licensing Department, Securities Division |
|---|---|
| Filing fee | $300 firm filing fee for initial registration and each renewal (NMSA 58-13C-410(C)), plus $50 per investment adviser representative for initial, renewal, or change of registration. IARD adds a one-time $10 setup fee and $10 annual maintenance fee per IAR. |
| Exam requirements | Series 65, or Series 7 plus Series 66 (post-1999 versions), passed within the two years before filing unless you have had no lapse in registration exceeding two years (12.11.5.14 and 12.11.5.16 NMAC). Waived for a current CFA, CIC, CFP, ChFC, or PFS designation. Firms with more than one registered person also need a designated supervisor who passed the Series 24 or Series 9/10 within the prior two years, unless waived by designation. |
| De minimis rule | An adviser without a place of business in New Mexico is exempt if it had not more than five New Mexico resident clients during the preceding 12 months, beyond institutional and certain other excluded clients (NMSA 58-13C-403(B)). |
| Bond requirements | Every adviser must maintain at least $5,000 net worth; discretionary authority raises it to $10,000. Custody requires $2,000,000 minimum net worth or a surety bond set by the director up to $2,000,000 (12.11.5.23 NMAC). Out-of-state firms meet their home state's requirement instead. A drop below the minimum must be reported by the next business day. |
New Mexico RIA registration runs through the Securities Division of the New Mexico Regulation and Licensing Department. If your firm manages less than $100 million in assets and operates from New Mexico, you register with the state rather than the SEC, filing the core forms through the national IARD system and mailing a package of supporting documents directly to Santa Fe. New Mexico publishes an unusually complete registration packet, which makes the requirements easy to verify but also easy to underestimate, because several of them, including a two-year exam window and a supervisor exam, do not exist in most neighboring states. This guide walks through the fees, exams, financial requirements, and filings, and you can compare other states in our RIA registration guides for every state.
The numbers first. The firm filing fee is $300 for initial registration and for each renewal, and every investment adviser representative costs $50 to register, renew, or transfer, with IARD adding a one-time $10 setup fee and a $10 annual maintenance fee per person. Each representative needs a passing grade on the Series 65, or on both the Series 7 and Series 66, earned within the two years before the application unless registration has continued without a lapse longer than two years. A current CFA, CIC, CFP, ChFC, or PFS designation waives the exams. Financially, every adviser must maintain at least $5,000 in net worth, $10,000 with discretionary authority, and an adviser with custody must maintain $2,000,000 in net worth or post a surety bond the director sets up to that amount. An out-of-state adviser stays exempt while it has no New Mexico place of business and not more than five New Mexico resident clients in the preceding 12 months.
You start by entitling your firm with IARD and funding the flex account, then file Form ADV Parts 1A and 1B, identifying New Mexico in Part 1B, with the Part 2A brochure and Part 2B supplements uploaded as searchable PDFs. Each representative files a Form U4 through CRD; New Mexico does not require fingerprint cards. A second track runs by mail: directly to the Division you send your most recent financial statements (unaudited is acceptable without custody, dated no more than 90 days before filing), a statement of financial condition if you will exercise discretion, a copy of your written privacy policy, specimen copies of every client contract you intend to use, solicitor agreements and disclosures if you pay for referrals, and a list of any New Mexico branch offices. If the Division finds deficiencies, it sends a letter giving you 60 days to respond, and an application still incomplete after six months can be denied outright.
Two clocks catch applicants. The first is the exam window: New Mexico wants your Series 65 or 7-and-66 scores earned within the two years before filing, so advisers who tested early and filed late can be sent back to the testing center unless continuous registration in another state bridges the gap. The second is the supervisor rule: a firm with more than one registered person must have a designated supervisor who passed the Series 24 or Series 9/10 within the prior two years or who holds one of the accepted designations, and that supervisor requirement extends to every New Mexico branch office. Solo advisers are spared, but the moment you add a second representative, the principal exam requirement arrives with them.
Because New Mexico reads your contracts and financial statements directly, sloppy documents become deficiency letters. Write the ADV Part 2A brochure in plain English covering services, fees, conflicts, and discipline, and make your advisory agreement match it exactly; New Mexico’s written contract rule requires the agreement to state the services, term, fee, fee formula, refund terms, whether you hold discretion, and a no-assignment clause. Prepare Part 2B supplements for each adviser and confirm every U4 answer, especially employment history and disclosure questions. Your privacy policy, code of ethics, compliance procedures, and books and records system must exist when you file, not after approval, because the privacy policy ships with the application. If you are building all of this for the first time, our overview of things you should know when starting an RIA from scratch lays out the full document map.
All New Mexico registrations end on December 31, and the Division recommends starting the IARD renewal in early November to avoid an accidental failure to renew; renewal fees match the initial fees. File annual financial statements with the Division within 90 days of your fiscal year end, which means March 31 for most firms, with audited statements and Form ADV-E required only when you have custody. Keep the ADV current with an annual updating amendment and file corrections within 30 days of any material change, including changes to each U4. When a representative leaves, notify the Division within 15 days by filing Form U5. Watch your net worth continuously: if it drops below the minimum, you must notify the director by the close of the next business day and follow with a detailed financial report.
Registration is state by state, so expansion means checking the de minimis rule wherever your clients live. New Mexico’s threshold allows an out-of-state adviser not more than five New Mexico resident clients in 12 months before registration is required, and most states apply a similar five-client cutoff with their own wrinkles. Count clients by state, watch preexisting relationships when clients relocate, and file before the sixth client signs. If your practice grows eastward, our Texas RIA registration guide covers the largest neighboring market and its very different process.
New Mexico’s two-track filing rewards preparation: firms that send a complete, consistent package to both IARD and Santa Fe get approved, and firms that improvise get deficiency letters. We assemble the whole submission for you, the ADV, the U4s, the advisory agreement, the privacy policy, and the compliance program, timed around the exam windows that trip people up. Talk with SimplyRIA before you file and start your firm without the false starts.
The firm filing fee is $300 for initial registration and for each annual renewal, and each investment adviser representative is $50 for initial registration, renewal, or a change of registration. IARD also charges a one-time $10 setup fee and a $10 annual maintenance fee per representative.
Each representative needs a passing grade on the Series 65, or on both the Series 7 and Series 66, earned within the two years before filing unless there has been no lapse in registration longer than two years. New Mexico waives the exams for a current CFA, CIC, CFP, ChFC, or PFS designation.
Yes, when the firm has more than one registered person. The designated supervisor must have passed the Series 24 or Series 9/10 within the two years before the application, or hold one of the accepted professional designations. A solo adviser does not need a separate designated supervisor.
Every registered adviser must maintain a minimum net worth of $5,000, rising to $10,000 with discretionary authority. An adviser with custody of client funds or securities must maintain a $2,000,000 minimum net worth or post a surety bond set by the director up to that amount.
An adviser without a place of business in New Mexico is exempt if it had not more than five New Mexico resident clients during the preceding 12 months, in addition to certain institutional clients that do not count toward the limit.
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