State-registered RIAs' assets top $360B as firm count slips, NASAA says

State-registered RIAs ended 2024 with $361.8 billion in assets under management even as their ranks edged down, according to the latest annual report from the North American Securities Administrators Association.

In its 2025 Annual Report published Monday, NASAA said there were 16,575 firms registered at the home state level by the end of last year.

All told, the report counted a $18.5 billion increase in AUM from the prior year alongside a net decrease of 322 firms.

“These firms are often small businesses deeply rooted in the neighborhoods they serve, and state securities regulators are committed to providing them with the tools and guidance they need to thrive while protecting investors,” NASAA president Leslie Van Buskirk said in a statement unveiling the data.

By NASAA's count, California hosted the most home state-registered investment advisers (2,641), followed by Texas (1,370), Florida (1,222), New York (720), and Illinois (644).

Counting both in‑state and out‑of‑state registrations, Texas led the way (4,618) ahead of California (3,548) and Florida (1,984).

The latest census of state RIAs found a total of 27,782 firms, more than 98% of which had 10 employees or less. Drilling down by the type of registration, NASAA said state RIAs collectively employed 11,541 broker-dealer registered reps and 47,263 investment adviser representatives, as well as 3,782 IARs with more than one firm.

Collectively, the report said the industry served almost 1.35 million clients, including nearly 275,000 high-net-worth individuals and just over 1 million retail investors.

The report caps a year in which exam teams continued to resolve deficiencies and violations. For 2024, NASAA said the top triggers of enforcement actions included failure to register as an RIA or representative, improper fee practices, fiduciary duty lapses, and inadequate compliance policies and procedures, with additional issues around conflicts disclosures, fraud – a top concern in last year's enforcement report – private placements, and custody.

“This annual report reflects NASAA’s continued commitment to supporting state-registered investment advisers and protecting retail investors through effective regulation, outreach, and enforcement,” said Steve Brey, chair of the investment adviser section.

While NASAA oversees RIAs with $100 million or less in regulatory assets under management, the state-federal split could shift in the near term.

In April, SEC commissioner Mark Uyeda indicated that the agency is re‑examining the $100 million AUM line that generally separates state‑registered RIAs from federally registered advisers, noting the growth in the population of mid‑sized firms since Dodd‑Frank pushed many advisers to state supervision in 2012. At the time, Uyeda said there were 8,956 advisers with between $100 million and $1 billion in AUM, compared to just over 5,800 in 2012.

"In my view, it is time to re-examine the mid-size adviser regulatory split and consider whether it should be adjusted," Uyeda said at a joint event hosted by NASAA and the SEC. "Doing so could help to ensure Congress’s intent that the SEC focus on the larger, more complex investment advisers while the states concentrate their resources on the smaller firms."

There is no formal proposal yet, but industry chatter has floated potential ranges from $150 million to $250 million. Any increase would likely send certain mid‑sized firms back to state oversight, echoing the Dodd‑Frank “switch” that reassigned thousands of advisers more than a decade ago.

According to law firm Proskauer Rose, a change in the asset threshold could impact small-enough SEC-registered firms, forcing them to re-register with state regulators or, where applicable, claim available exemptions at the state level.

"The prospect of state-level registration may be bittersweet for some investment advisers," lawyers at the firm said in an April note. "While some advisers may be eager to escape from SEC jurisdiction, state regulators may be less familiar with the complex transactions, fund structures and terms and other market practices .that are the norm across private funds."