A rapidly scaling fintech provider engaged InnReg to establish a US-based affiliate under a Registered Investment Advisor (RIA) framework. Operating from Australia, the fintech’s core product is a digital treasury management platform that empowers finance teams to automate yield optimization, monitor real-time cash positions, reduce manual complexity in cash flow and payments, and maintain liquidity oversight.
The US affiliate is being structured to offer non-discretionary robo-advisory services tailored to corporate clients, especially subsidiaries of international businesses. The objective is to deliver algorithmic guidance for idle corporate funds, leveraging short-duration, low-risk instruments, while clients make the ultimate investment decisions.
Objective
The client’s objective was to establish a US-based affiliate capable of operating as an RIA under SEC oversight. This affiliate would serve as the foundation for a robo-advisory platform designed for corporate treasury management.
The engagement required InnReg to:
Prepare and submit the SEC registration application, including all required Form ADV filings.
Develop compliance documentation, policies, and procedures tailored to the robo-advisory model.
Guide regulatory strategy and communications with the SEC during the registration process.
Support the design of the compliance technology stack, including custodian selection and integration with third-party vendors.
The overall goal was to deliver a complete compliance program that would allow the client to launch its robo-advisory business in the US while mitigating regulatory risks from day one.
See also:
Challenges
The engagement presented several compliance and regulatory challenges:
First-Time Registration: The US affiliate was newly formed, requiring a complete application for SEC registration.
Novel Business Model: The robo-advisory platform combined automated cash management technology with regulated advisory functions. This required customized compliance policies to address algorithmic recommendations, disclosure of risks, and the non-discretionary nature of services.
Technology and Custody Integration: The client needed to design a compliance-ready technology stack, including establishing custodial relationships and selecting vendors capable of supporting robo-advisory operations.
Regulatory Scrutiny: As a new market entrant with zero regulatory assets under management at launch, the client had to navigate SEC review and provide clear, well-documented responses to regulator inquiries.
InnReg's Solution
InnReg delivered a comprehensive, end-to-end support package tailored to the client’s launch of its US affiliate as a Registered Investment Advisor. Key elements included:
SEC Registration Support
Prepared and filed the client’s Form ADV Parts 1, 2, and 3.
Drafted required documentation, including compliance policies, procedures, and disclosures specific to a robo-advisory model.
Assisted in gathering and structuring corporate, ownership, and business model information for submission.
Regulatory Strategy and Communications
Coordinated communications with the SEC throughout the registration process.
Prepared written responses to regulator requests and guided the client on the most effective strategies to address follow-up questions.
Compliance Program Development
Designed a compliance framework addressing advisory activities, conflicts of interest, cybersecurity, personal trading, recordkeeping, and client communications.
Incorporated specific risk disclosures related to algorithmic recommendations, interest rate exposure, liquidity management, and technology dependencies.
Technology and Custody Enablement
Supported the design of the compliance technology stack, including vendor evaluation and onboarding.
Assisted with custodial arrangements by guiding negotiations and integration with a third-party custodian.
This solution provided the client with both regulatory approval and an operational compliance program aligned with its fintech-driven business model.
Client Results
The client achieved SEC approval to operate as an RIA in less than four months from the start of the engagement. This rapid timeline reflected both the completeness of the registration package and the strength of the compliance program developed during the process. By securing registration efficiently, the client was able to align its regulatory status with its planned market entry.
With a compliance framework in place, the client was ready to launch its robo-advisory service to corporate customers in the US.
How Can InnReg Help?
InnReg can help Registered Investment Advisors (RIAs) with regulatory strategy, SEC registration application and the compliance documentation and strategy that comes along with complex business models. If you would like support with the design of your comprehensive, end-to-end support package, reach out to us today.
