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Winthrop & Co.
Market Insights
GuideFiled October 7, 20266 min read

When Should a New RIA Hire Its First Employee?

When a new RIA should make its first hire, who that hire should be, whether to hire or outsource, and the compliance steps every hire sets off: the code of ethics, investment adviser representative registration on Form U4, the Form ADV Part 2B brochure supplement, and supervision. Tied to the SEC rules, NASAA guidance and Kitces Research behind each one.

Filed by Tyler Noe

GuideWhen Should a New RIA Hire Its First Employee? Timing, Roles and Compliance

The short answer: By Kitces Research's framework, a new RIA's first hire comes after the firm can afford a salary while still paying its owner and before the founder runs out of time for clients. Benchmarking data compiled by Kitces.com suggests many solo advisors reach that capacity point somewhere between 30 and 40 clients, and Kitces Research found that most firms hire a client service administrator first and an associate advisor second. Every hire also sets off compliance work: at an SEC-registered firm, each new supervised person receives and acknowledges the code of ethics, and a hire who gives advice may need state registration on Form U4 and a Form ADV Part 2B brochure supplement.

For a breakaway team that brings its staff along, these questions arrive on day one. For a founder who launches alone, they arrive with growth. Either way, the hire is part of the launch plan, alongside the steps in how to build your own RIA from scratch.

The first-hire options, side by side

First hireWhat it takes off the founderCompliance it usually triggers
Client service or operationsPaperwork and client service administrationSupervised person: at an SEC-registered firm, receives the code of ethics; an access person if the role sees nonpublic information about client trades. Usually no Part 2B if the role gives no advice and holds no discretion
Paraplanner or associate advisorFinancial planning and analysis, sometimes client meetingsEverything above, plus a Part 2B supplement if the person formulates advice with direct client contact or holds discretion, and investment adviser representative registration on Form U4 where the role meets the definition
Outsourced supportCompliance consulting, bookkeeping, part-time administrative helpThe firm stays responsible for the work; a person who gives advice on the firm's behalf under its supervision is a supervised person

When should a solo RIA make its first hire?

Kitces Research frames the decision with two thresholds. The capacity wall is the point where the founder reaches the maximum client workload and needs support to grow further; benchmarking data suggests many advisors reach it somewhere between 30 and 40 clients. The profitability wall is the revenue a firm needs to hire while still adequately paying the owner. The range between the two is the hiring zone, and the research suggests hiring inside it, before the founder has no time left to recruit and train anyone.

If the profitability wall sits too close to the capacity wall, or above it, the same research suggests working on capacity first, by streamlining processes or adjusting fees, before hiring.

In Kitces Research's 2022 study of how planners work, solo firms with no employees had a median of 40 clients per advisor, 2-person firms had 70, and 3-person firms had 96. For more on firms at this scale, see what a small RIA is; whether you can go independent with a small book works through the economics before any hire.

The median SEC-registered adviser had 8 employees in 2025, per the Investment Adviser Association's 2026 industry snapshot, and the average state-registered adviser had 1 non-clerical employee.

Who should the first hire be?

Most firms hire a client service administrator first and add an associate advisor second, according to Kitces Research. The right first role depends on what the founder needs to hand off. The paperwork-heavy client service work is often delegated first because founders tend to like it least, and an advisor who struggles with paperwork may start there, while one strong on systems and process may hire an associate advisor first and add client service later. A first hire can begin as a hybrid role and specialize as the firm grows.

Employee or outsourced?

Solo founders commonly outsource parts of the work, such as compliance consulting, bookkeeping or part-time administrative help. Outsourcing moves the tasks and keeps the responsibility: the founder still implements and manages that support, and switching among several outside providers through the day takes attention of its own.

Two legal lines matter here. The Advisers Act defines a supervised person to include any employee, and any other person who provides investment advice on the firm's behalf subject to its supervision and control, so an outsourced paraplanner who advises clients can fall inside the firm's compliance program. And for federal tax purposes, whether a worker is an employee or an independent contractor turns on control, which the IRS groups into behavioral, financial and relationship factors. Both are questions for counsel or a tax adviser before the offer goes out.

What compliance steps does a first hire trigger?

  1. Supervision. The Advisers Act lets the SEC sanction an adviser that fails reasonably to supervise a person who violates the securities laws. The defense is having procedures, and a system for applying them, reasonably expected to prevent and detect violations, and following them.
  2. The compliance program. An SEC-registered firm's written policies and procedures, reviewed at least once a year, should cover the new role; state-registered firms follow their state's equivalent rules.
  3. The code of ethics. At an SEC-registered firm, every supervised person receives the code of ethics and acknowledges it in writing. Access persons, those with nonpublic information about client trades or a role in recommendations, file a holdings report within 10 days of becoming one and transaction reports within 30 days of each quarter end.
  4. Registration. States register investment adviser representatives on Form U4 through the Central Registration Depository, including those of SEC-registered firms with a place of business in the state. For an SEC-registered firm, the federal definition covers supervised persons with more than five clients who are natural persons, where natural persons are more than ten percent of their clients, and excludes those who do not regularly solicit, meet with or communicate with clients. Most states that license representatives require the Series 65 or an equivalent.
  5. Form ADV Part 2B. A brochure supplement is required for any supervised person who formulates investment advice and has direct client contact, or who holds discretionary authority over client assets, and is delivered before or at the time that person begins serving the client. SEC-registered firms keep supplements on file; state-registered firms file them with each state where the person does business.

Whether a particular role crosses these lines is a question for counsel or the firm's compliance support.

Staffing is one of the decisions Winthrop's RIA Search & Launch works through with advisors building a firm, alongside registration, the custodian and the day of resignation. To plan the launch on paper, start with the RIA Launch Checklist. Request an introduction.

Sources (13)

Frequently asked

When should a solo RIA hire its first employee?
Ideally after the firm can afford a salary while still paying the owner and before the founder runs out of time for clients, per Kitces Research. Benchmarking data compiled by Kitces.com suggests many solo advisors reach that capacity point somewhere between 30 and 40 clients. If the firm reaches capacity before it can afford a hire, streamlining processes or adjusting fees may come first.
Who should a new RIA hire first?
Most firms hire a client service administrator first, per Kitces Research, and add an associate advisor second. The right first role depends on what the founder most needs to hand off: an advisor who struggles with paperwork may start with client service, while one strong on systems and process may hire an associate advisor first.
Should a new RIA's first hire be an employee or outsourced?
Either can work. Solo firms often outsource compliance support or bookkeeping, but the founder still manages that work and remains responsible for it. For federal tax purposes, whether a particular worker is an employee or an independent contractor turns on the degree of control, which the IRS groups into behavioral, financial and relationship factors; that classification is a question for counsel or a tax adviser.
Does a new RIA employee need to register as an investment adviser representative?
It depends on what the person does and where. States register investment adviser representatives, including those at SEC-registered firms with a place of business in the state, using Form U4. For an SEC-registered firm, the federal definition covers supervised persons with more than five clients who are natural persons, where natural persons are more than ten percent of their clients, and excludes those who do not regularly solicit, meet with or communicate with clients or who give only impersonal advice.
Does every RIA employee need a Form ADV Part 2B?
No. A brochure supplement is required for any supervised person who formulates investment advice for a client and has direct client contact, and for any supervised person with discretionary authority over a client's assets. It is delivered before or at the time that person begins providing advisory services to the client.
Do new employees have to follow the RIA's code of ethics?
At an SEC-registered firm, yes. Every supervised person receives a copy of the code of ethics and acknowledges it in writing. Access persons, those with nonpublic information about client trades or involvement in recommendations, file a holdings report within 10 days of becoming one and quarterly transaction reports within 30 days of each quarter end. State-registered firms follow their state's rules.

Filed

October 7, 2026

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