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Investment Advisor Registration Requirements for Illinois
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Registering as an RIA in Illinois — What You Need to Know
Illinois may not be known for splashy regulatory announcements but that doesn’t mean expectations are low. The Illinois Securities Department quietly enforces one of the most documentation-driven RIA registration processes in the country. If your policies, financials, and disclosures don’t match, examiners will flag it.
Whether you’re preparing for first-time registration or managing an ongoing program, Comply helps Illinois-based firms stay organized, exam-ready, and aligned with the state’s evolving standards.
Why Illinois Compliance Is So Demanding
Illinois examiners are thorough and consistent – and expect your firm to be, too. Here’s what makes compliance in the state more intensive than most RIAs realize:
Recordkeeping is king – Examiners expect documented reviews, policies, agreements, and trade records
Cybersecurity isn’t optional – Policies must meet SEC standards even without a state mandate
Filing accuracy matters – Inconsistent ADV, contract, or website language will be flagged
Exams are regular and rigorous – Illinois won’t wait years between reviews
Supervision must be proven – You’ll need to show ongoing oversight, not just policy language
Custody brings extra scrutiny – Audited financials required if client assets are held
Comply Tip: We help firms keep their documentation exam-ready year-round—so nothing falls through the cracks when Illinois comes calling.
One Partner for Registration, Renewal, and Ongoing Compliance
Comply helps investment advisers in Illinois with:
Initial registration, including ADV prep, financial documentation, and policy development
Annual renewals and filings with fee tracking and deadline reminders
Form U4/U5 filings for adviser onboarding or termination
Customized policies covering cybersecurity, personal trading, supervision, and privacy
Exam readiness tools including review workflows and documentation checklists
Hands-on support from former regulators who understand the Illinois review process
We thought Illinois would be easy; but it wasn’t. Comply helped us get ahead of what the state wanted and avoid back-and-forth that would’ve dragged out our registration
RIA COO, Chicago
Frequently Asked Questions
You've got questions. We've got answers.
Have questions about investment registration requirements in Illinois? Check out some of the most frequently asked questions for all your answers.
RIAs in Illinois are regulated by the Illinois Securities Department, a division of the Illinois Secretary of State. The Department enforces the Illinois Securities Law of 1953 and relevant federal rules under the Investment Advisers Act of 1940. All filings and updates go through FINRA’s IARD and CRD systems, but Illinois regulators manually review documentation and often request clarification during the process.
To register in Illinois, advisers must file through IARD and submit:
Form ADV Parts 1 and 2 reflecting the firm’s structure and services.
Advisory agreements and disclosures consistent with ADV language.
Financial statements, with audited financials required if the firm has custody.
Written supervisory and compliance policies, including cybersecurity and privacy measures. Illinois examiners expect detailed, firm-specific documentation boilerplate language or inconsistencies are common triggers for deficiency letters.
Illinois investment advisers must meet the following ongoing filing obligations:
ADV annual amendment: Due within 90 days of fiscal year-end.
IARD renewal fees: Typically due each November–December ($200 per firm; $150 per IAR).
Form U-5: Must be filed within 30 days of an IAR’s termination.
Audited financials: Required if the firm holds custody of client funds or assets. Missing or late filings can lead to penalties, delays, or increased scrutiny during exams.
Recordkeeping: Detailed transaction records, personal trading reviews, and documented annual compliance reviews.
Cybersecurity and privacy: While not prescriptive, Illinois expects firms to maintain written policies aligned with SEC standards.
Exam readiness: Illinois conducts frequent, thorough exams, so firms must maintain documentation in a “ready-for-exam” state. This emphasis makes Illinois one of the more detail-oriented states for RIA oversight.
