Frequently Asked Questions About Joining APFORIA as a Tenant Firm

APFORIA — short for Atlantic to Pacific Fee-Only Registered Investment Adviser — is a privately held, SEC-registered investment adviser incorporated in the Commonwealth of Virginia in May 2023 and registered with the Securities and Exchange Commission in August 2023 under the Investment Advisers Act of 1940. APFORIA operates as an umbrella RIA, meaning independent financial advisory firms operate under APFORIA's SEC registration as Tenant Firms, using their own names and brands while APFORIA handles compliance, registration, and back-office infrastructure.

An umbrella RIA is an SEC-registered investment adviser that allows multiple independent advisory practices to operate under a single registration. At APFORIA, each practice is called a Tenant Firm. Tenant Firms maintain their own client relationships, their own brand identity, and their own way of doing business — they operate as "APFORIA dba [Firm Name]." What APFORIA provides is everything behind the scenes: SEC registration, compliance oversight, a dedicated Chief Compliance Officer, books and records management, annual training, and technology infrastructure. The result is that advisors get the autonomy of an independent practice with the regulatory support of a larger organization, and clients interact only with the Tenant Firm they know and trust.

APFORIA exists to create a sustainable platform that facilitates the formation and growth of small, independent fee-only advisory firms. We do this by providing SEC registration, compliance management, and back-office services to our investment adviser representatives so they can focus entirely on serving their clients and building their practices — rather than managing regulatory overhead. We believe that when advisors are supported and freed from compliance burden, they do their best work for clients.

APFORIA is a fee-only registered investment adviser — not a broker-dealer and not an Office of Supervisory Jurisdiction (OSJ). That distinction matters significantly. Broker-dealers and OSJs permit commission-based compensation, which creates inherent conflicts of interest between the advisor and the client. APFORIA does not permit commissions of any kind. Every advisor in the APFORIA network is a fiduciary 100% of the time, legally obligated to act in the client's best interest. There are no revenue-sharing arrangements, no product sales incentives, and no exceptions to the fee-only policy.

Yes, without exception. Fee-only is foundational to APFORIA. We do not permit any form of commission-based compensation. Many of our adviser representatives hold the CFP® designation and hold themselves out as fee-only financial planners; the CFP Board of Standards requires the entire firm to be fee-only when a CFP® Professional represents themselves as such. All Tenant Firms and their adviser representatives must comply with APFORIA's fee-only policy as a condition of membership.

No. Fee-based and fee-only are not the same thing. Fee-based advisers accept both client fees and third-party commissions, which creates conflicts of interest that are incompatible with APFORIA's fiduciary model. APFORIA is exclusively for advisors who receive 100% of their compensation directly from clients, with no commissions, referral fees, or compensation from product providers of any kind. If you are currently fee-based but considering a transition to a fully fee-only model, we are happy to have a conversation about what that path might look like.

There are no client or asset minimums required to join APFORIA as a Tenant Firm. Whether you are launching a new advisory practice or transitioning an existing book of business, you are welcome to begin your journey with us. We have a supportive community of adviser representatives who are experienced in helping new members get started and grow.

APFORIA charges a sliding scale fee of 10% to 15% of your advisory revenue. The minimum annual fee is $12,000, with a temporary pricing accommodation available for new adviser representatives who are in the early stages of building their practice and generating very low revenue. In addition to the revenue-based fee, there is a membership and technology fee that covers a portion of the cost of the technology stack APFORIA maintains on behalf of all Tenant Firms. We encourage prospective members to schedule a consultation to discuss fee specifics in the context of their individual situation.

APFORIA's compliance program is designed to handle the vast majority of your regulatory obligations so you can focus on your clients. It includes SEC registration for the firm and all adviser representatives, a dedicated Chief Compliance Officer (CCO) who provides ongoing oversight and supervision, an annual compliance training program, a structured compliance calendar with both scheduled and as-needed tasks, books and records management guidance consistent with the firm's Compliance Manual, Code of Ethics enforcement, and business continuity planning. Our goal is for Tenant Firms to never have to speak directly with a securities regulator.

Our goal is never. While securities regulators have the authority to examine or contact adviser representatives at their discretion, a well-run compliance program significantly reduces that likelihood. APFORIA's Compliance Team handles your registration and the large majority of your ongoing compliance activities. As a Supervised Person under APFORIA, you will have defined responsibilities — but we handle the infrastructure. It is our goal that your experience with regulators is limited to what you choose to know about, not what lands in your inbox uninvited.

No. APFORIA does not authorize custody of client funds or securities by adviser representatives. Client assets are held at independent, qualified custodians. This is a firm-wide policy with no exceptions, and it is consistent with APFORIA's commitment to operating a clean, conflict-free advisory model that protects clients.

APFORIA does not permit dual registration as both an investment adviser representative and a registered representative of a broker-dealer. We also generally do not allow adviser representatives to be registered with more than one investment adviser at the same time. There may be brief, unavoidable overlap during onboarding or offboarding transitions, which we handle on a case-by-case basis in coordination with our compliance team.

Yes. Your clients are your clients. If you decide to leave APFORIA, clients are free to follow you to your new registration or remain with APFORIA — that choice belongs to them. It is worth knowing that the process of registering independently or with a new firm and re-papering client accounts typically takes several months. During that transition period, you will be required to honor your existing agreements with APFORIA. We encourage all prospective members to review the membership agreement carefully before joining, and we are happy to walk through that process transparently during a consultation.

Yes. You do not need prior experience as a registered investment adviser representative to join APFORIA. We have a collaborative community of experienced adviser representatives who are genuinely invested in helping newer members build their practices and serve their clients well. APFORIA's compliance infrastructure and back-office support are especially valuable for advisors who are new to the registration and regulatory side of running an advisory firm. If you hold relevant credentials (CFP®, MQFP®, or similar) and are committed to a fee-only, fiduciary model, we welcome a conversation.

Indeed — it is the only thing that ever has.