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The Practice

State-registered advisers now number 16,897, and oversight follows the rep

NASAA's annual report sizes the sub-$100 million practice and shows why changing a firm's registration doesn't move its people out of state reach.

State securities regulators counted 16,897 investment advisers in the latest census, each managing $100 million or less, and the less-cited fact in NASAA's September 2024 Investment Adviser Section report is that state oversight reaches every investment adviser representative no matter where the firm files. Published by an organization founded in 1919 and still the oldest international investor-protection body, the annual report sets out the state-registered population's size, growth, and rulemaking agenda in one document, making it the closest thing a small practice gets to a census of its own segment.

NASAA President Claire McHenry reads the count as a growth story and describes the population as small and mid-sized businesses, while the regulators' stated goal is helping those firms serve clients and stay current with state securities law. The report's updated adviser profile gives a practice below the $100 million line a baseline to size itself against, which turns the document into a compliance benchmark as much as an industry snapshot: the segment is expanding, and a state office is the primary regulator of record.

The most useful line may be the least-cited one. State oversight extends beyond the 16,897 firms to every investment adviser representative who works directly with retail investors, whether the adviser files with a state or with the SEC, and changing a firm's registration does not move its people out of state jurisdiction — the representative layer remains a permanent compliance population independent of where the firm registers.

The rulemaking section puts cybersecurity first. NASAA's Cybersecurity and Technology Project Group is promoting adoption of the association's model rules and helping advisers use technology effectively, according to Alisa Goldberg, director of the Florida Office of Financial Regulation and chair of the Investment Adviser Section, and the report also catalogues proactive outreach and the committee's education and training work. NASAA's rulemaking did not stop with the report: in August 2026 the association cut the retest waiting period to 60 days after a third failure, letting candidates retake four months sooner, as this publication reported.

For a practice below the $100 million line, the compliance denominator is representative headcount, not the registration form on file. The 16,897 figure will drift as firms cross the threshold, but representatives stay under state supervision at state-registered and SEC-registered firms alike, and the cybersecurity model rules are where state exams are likely to look first. A practice that sizes its compliance workload by the people it employs has the right measure.

Sources & further reading
NASAA News
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