Can You Still Sell Insurance and Annuities After You Go RIA?

The short answer: Your insurance license is yours. Under the NAIC's model law, which states enact in their own versions, it stays in force when you leave a broker-dealer, though in some states the variable line does not. What can end is any insurer appointment and agency contract that ran through the broker-dealer, so you may be appointed again through a new agency. Fixed and fixed indexed annuities and fixed life insurance are insurance products, so an RIA advisor with a license and an appointment is generally able to sell them on commission. Variable annuities, registered index-linked annuities and variable life insurance are also securities, so their commissions, and the trails on them and on mutual funds, come only through a broker-dealer. At the RIA, every commission is a conflict the firm discloses, and your compliance officer decides how it is handled.

More of the RIA channel now runs this way. Cerulli Associates research reported by WealthManagement.com in October 2026, in a white paper commissioned by an RIA, found that among independent RIAs with $5 billion or more in assets, firms whose advisors keep state insurance licenses went from 7% to 14% of the group's assets between 2020 and 2025, while true fee-only firms went from 42% to 34%. Among all SEC-registered advisers, the Investment Adviser Association's 2026 Snapshot counts 22.4% that are, or are affiliated with, an insurance broker or agent, up from 13.1% in 2001.

Is your insurance license yours?

Yes. Under the NAIC's model licensing law, which states enact in their own versions, a state licenses the individual producer for each line of authority, and the license stays in force while the renewal fee is paid and continuing education is met. Nothing in the model ties it to a broker-dealer.

Three other things can end or change when you leave:

• Appointments. In states that require them, an insurer appoints a producer before the producer acts for it, and under the NAIC model the insurer reports a termination within 30 days. An appointment held through your broker-dealer's agency can end with that contract, and new appointments then run through the agency you contract with next: an independent agency or marketing organization, a brokerage general agency, or a broker-dealer's agency if you keep one.
• The agency contract. If your insurance business ran through your broker-dealer's affiliated agency, that contract, and the carrier's agent contract, decide who is agent of record on in-force policies and who receives renewals.
• The variable line. In some states it follows your FINRA registration. Indiana, for example, treats a producer who is no longer registered with FINRA as no longer eligible for the variable life and annuity line, which must be cancelled before the license is renewed.

The NAIC best-interest model also requires producers to complete a one-time annuity training course before selling annuities. An insurer can require you to be appointed before you service an existing contract, which how client accounts move when you change firms covers for the transfer itself.

Which products need what?

The line runs through securities law. FINRA's rules say an associated person of a member firm may generally accept compensation on variable contracts and mutual funds only from that member, and the SEC's guide says unregistered entities may not receive commission income on behalf of a registered representative. That is why a hybrid keeps a broker-dealer registration, as what a hybrid RIA is sets out.

What happens to your trails?

Securities trails stop without a broker-dealer registration. FINRA Rule 2040 bars member firms from paying commissions to someone who is not registered but would need to be to receive them, and the SEC's broker-dealer guide lists trailing commissions such as 12b-1 fees among the activities that point to broker registration. A trail cannot be redirected to your RIA either.

The retiring-representative exception is for retirement. Rule 2040 allows continuing commissions to a representative who retires and leaves the securities industry under a contract made while registered. FINRA's 2022 succession-planning notice lists the conditions, including that the retiring representative not be associated with any investment adviser while the agreement runs, which rules out an advisor joining or starting an RIA.

An unmoved product stays where it is. A directly held fund or variable annuity stays on your old broker-dealer's books unless the client consents to move it to another broker-dealer of record. NASD staff described that change as mainly affecting who receives the fees and commissions the issuer pays, and said firms should obtain the customer's affirmative consent for it.

That leaves the three paths lapsing your Series 7 describes: keep a broker-dealer affiliation for the trails, convert the assets to advisory, or let the trails go. Converting often means moving to a share class without 12b-1 fees; in June 2026 the SEC's examiners described advisers whose clients held fund share classes paying 12b-1 fees to the adviser or its representatives when a lower-cost class of the same fund was available.

Insurance renewals follow different rules. The NAIC model says renewal or other deferred commissions may be paid to a person who was licensed when the policy was sold, and states enact their own versions. Whether renewals keep coming to you depends on your state, the carrier's agent contract and any agency contract. Read those contracts, with your own attorney where needed, before the move.

What changes at the RIA?

Disclosure. Form ADV asks about insurance activity in several places: in Part 1A, how many employees are licensed insurance agents, whether the firm is an insurance broker or agent, and whether a related person is an insurance company or agency; in the Part 2A brochure, the conflict when the adviser or its people accept compensation for selling investment products, material relationships with insurance companies or agencies, and economic benefits from non-clients; and in each advisor's Part 2B supplement, other business activities, including commissions and trails.

The fiduciary duty covers the whole relationship. The SEC's 2019 interpretation says the adviser's duty applies to all advice it gives, including advice about account type, and that a conflict must be eliminated or fully and fairly disclosed so the client can consent. Among advisers, the SEC's fiscal 2026 exam priorities name firms dually registered as broker-dealers, particularly where their advisory representatives are also registered representatives; its broker-dealer exams under Regulation Best Interest focus on complex products such as variable and registered index-linked annuities. In February 2026 a federal court entered final judgment in an SEC case against an adviser over undisclosed incentives in fixed indexed annuity sales to advisory clients, after a jury found liability under Section 206(2) of the Advisers Act.

Fee-only means no commissions. Under CFP Board's standard, a CFP professional may describe compensation as fee-only only when the professional and the firm receive no sales-related compensation, a list that includes commissions and trailing commissions. CFP Board's term for a professional paid both fees and sales-related compensation is fee and commission.

Annuity best interest applies too. NAIC's map shows its 2020 annuity best-interest model adopted in 49 jurisdictions as of August 31, 2026, with the District of Columbia pending and New York under its own rule. The model lets an investment adviser representative acting under the Advisers Act fiduciary duty rely on that duty to satisfy the state rule, where the insurer meets the model's monitoring conditions; each state decides whether state-registered advisers are covered. The Department of Labor's 2024 fiduciary rule never took effect: courts stayed and then vacated it, and the Department's notice conforming its regulations took effect April 20, 2026. For retirement accounts, the Department's earlier five-part test and its exemptions still apply.

Which of these paths fits depends on your book of business: how much of it sits in variable products, how much in fixed and life policies, and how your clients would see a change in how you are paid. What your licenses, contracts and registrations allow in your case is a question for your own compliance officer and attorney. Whether to keep a broker-dealer in the picture, and what the firms that fit would look like, is a confidential conversation that draws on Winthrop's relationships and its record of past deals, and on how culture, technology, support and service differ from one firm to the next. Leaving an independent broker-dealer covers the rest of the exit. The firm pays Winthrop & Co., and the advisor never pays. Request an Introduction.