Of 271 federally registered internet advisers, 107 told the SEC they had no clients.

Start with the document that closed the door, because it is published, dated, and counts its own subjects. Release No. IA-6578, Exemption for Certain Investment Advisers Operating Through the Internet, File No. S7-13-23, adopted 27 March 2024 and published in the Federal Register on 9 April 2024. Rule 203A-2(e) had since 2002 let an adviser register with the Commission, regardless of size, if it advised clients through an interactive website — with an allowance for “fewer than 15” non-internet clients in the preceding twelve months. The amendments delete that allowance: an adviser “must provide advice to all of its clients exclusively through an operational interactive website,” defined as a website or mobile application “or similar digital platform” through which it provides digital advisory services on an ongoing basis to more than one client, with a carve-out only for “temporary technological outages of a de minimis duration.”

Then the census. “As of June 2023” there were 15,391 registered investment advisers. Of these, 261 — 1.70% — relied exclusively on the internet exemption, “with a combined total of $1.09 billion in regulatory assets under management.” Ten more were dually registered, making 271; of those, 197 held under $25 million. And the line that should have ended the argument: “As of June 2023, 107 advisers (39% of 271) reported advising 0 clients,” with a further five advising exactly one. The Commission also recorded that its examination programme “has identified multiple instances of compliance issues relating to advisers relying on the exemption without an interactive website.”

Divide and the picture is unambiguous. $1.09bn ÷ 261 = $4,176,245 of regulatory assets per firm, against a statutory federal floor of $100 million. The cohort averaged 4.18% of the minimum the Commission applies to everybody else. Two in five had no client at all. This was not a population of small advisers doing business on the internet; it was, for a substantial share of it, a federal registration held by somebody who was not advising anyone. The remedy was blunt: amend Form ADV to represent eligibility by 31 March 2025, or register with one or more states and file Form ADV-W by 29 June 2025. The Commission costed the exit at “$319 per adviser.”

Now the part almost nobody put next to it. While the federal side-door was closing, the ordinary state door was being made cheaper. NASAA’s 2026 fee announcement, dated 17 September 2025 and quoting its president Marni Rock Gibson, says “there will be no changes to the Investment Adviser Registration Depository (IARD) system fees for 2026,” and the 2026 renewal bulletin prints what those are: for a state-registered investment adviser firm, $0 — “NASAA continues to waive this fee” — and for each representative, $15. The representative fee was $45 when the system went live in 2001, a 66.7% cut in nominal terms across twenty-five years of inflation.

Set that against what the Commission’s own filing agent charges the firms that did clear the threshold. The SEC’s IARD filing-fee page lists, for SEC-registered advisers, $225 initial and $225 for each annual updating amendment at $100 million or more of assets; $150 between $25 million and $100 million; and $40 below $25 million. So a firm managing a hundred billion dollars pays $225 a year to keep its federal registration current, and a one-person state-registered firm pays $15. The ratio is 15× in the giant’s disfavour and both numbers are, in any serious sense, zero.

Add up what it actually costs one person to be legally entitled to charge for investment advice in the United States today. The Series 65 examination, administered for NASAA by FINRA, is $187; you pass by answering 92 of 130 questions, and an unsponsored candidate enrols directly through FINRA’s Test Enrollment Services System and gets a 120-day window. The Texas State Securities Board charges $75 for the firm application and $35 for each investment adviser representative, and asks for a balance sheet certified on its Form 133.18. IARD takes $15 for the representative and nothing for the firm. 187 + 75 + 35 + 15 = $312. NASAA’s model rule on minimum financial requirements imposes a net worth floor of $35,000 on an adviser with custody and $10,000 on one with discretionary authority — and nothing at all on one with neither, who merely has to stay positive if it takes more than $500 of fees more than six months in advance. A non-discretionary, non-custodial, fee-only solo adviser has no capital requirement.

Here is the reading almost nobody holds. The public argument about who may charge for financial advice is conducted as though entry were the problem — licensing, gatekeeping, the moat around the profession. The fee schedules say entry costs $312 and the capital requirement is $0. What the schedules also say, read together, is that the thing entry gets you is almost nothing. NASAA’s Investment Adviser Section report for 2025 counts 16,575 state-registered firms at 31 December 2024, down 322 on the year, holding $380,337,176,208 between them — an average of $22,946,436 a firm. The Investment Adviser Association’s 2026 snapshot, published 3 June 2026, counts 16,544 SEC-registered advisers holding $176.8 trillion. Almost exactly the same number of firms. 465× the assets per firm. The state-registered half of the American advice industry holds 0.22% of the money.

Which is the whole finding. The licence is not scarce and never was; the binding input is client assets, and the fee schedule tells you precisely how little the paperwork costs by comparison. At a 1% annual fee, a single client account of $31,200 pays the entire first-year cost of being a registered investment adviser in America. $5,000 a month, however, is $60,000 a year gross, which is $6,000,000 of client assets at that rate — and after self-employment tax and 2026 federal income tax on a single filer with no other income, $7,837,305. The tax, expressed in the only currency this business has, costs $1,837,305 of client money. Two in five of the cohort the Commission counted never found the first dollar of it.