Written by: Javi Otero
Starting or Joining an RIA: The 3 Types of Transitions
If you’re a financial advisor considering a transition, the first (and arguably most critical) step is understanding the type of transition you’ll be executing upon your departure. Why? Because the type of transition will determine the types of information you can bring with you, how you will communicate with clients, and what risks you could be exposed to during the move.
In today’s landscape, there are three primary types of transitions:
- Non-Protocol
- Protocol
- Protocol Not Applicable (PNA)
Each transition type comes with its own level of compliance risk, timeline considerations, data allowances, and operational demands. Not understanding which category applies to your situation, or ignoring the nuances, can lead to costly missteps – from delayed client onboarding to legal issues that stall your transition entirely.
This guide is designed to walk you through the details of each scenario so you can plan accordingly, avoid unnecessary headaches, and keep your momentum during an important career move.
Disclaimer: The content in this blog post is for informational purposes only and does not constitute legal, compliance, or regulatory advice.
Understanding the Transition Types
Non-Protocol Transitions
The Broker Protocol was executed in 2004 and governs the use of client information when registered reps move between firms that are signatories to the Protocol. If you’re leaving a non-protocol firm — such as Edward Jones, Merrill Lynch (post-2018), Morgan Stanley (post-2017), or many others — it’s critical to understand that your transition will be the most restrictive in terms of what you can legally take with you.
When operating under non-protocol restrictions, you generally cannot take any client data with you at the time of your resignation. That means no spreadsheets, no CRM exports, no account statements, no client notes — nothing that could be considered the firm’s intellectual property or confidential information.
This restriction exists to protect the firm’s ownership of client relationships, and violations can trigger serious legal consequences, including temporary restraining orders, lawsuits, and reputational damage that could derail your transition before it truly begins.
Because of these restrictions, non-protocol transitions require extreme discipline and strategic planning. We highly recommend you have your current contract reviewed by a securities attorney to determine the specifics of your situation.
Consider the situation a rebuild with a full repapering.
You’ll likely need to rely on public information and personal memory to re-establish relationships with clients. Sourcing contact information like publicly listed addresses and phone numbers — with no access no proprietary internal documents or systems.
Critical Tips:
- Confidentiality is critical: Do not share your plans with anyone internally — even trusted CSAs are firm employees. We’ve witnessed situations end in premature terminations because the wrong person was let inside the circle of trust.
- Engage an industry attorney early: Before you take a single step, have your contracts reviewed by a securities attorney to interpret non-solicits, non-competes, and confidentiality clauses.
- Prepare your “post-resignation” plan: Recreate your client (now prospect) list with the public information you sourced. Craft the message and practice what you want to say to your clients. Have a marketing, outreach, and re-engagement strategy prepared.
Protocol Transitions
If you’re currently affiliated with a Protocol firm and are transitioning to another firm that is also a member of the Broker Protocol, your process will have more flexibility than a non-protocol situation. However, it still requires caution and precise execution.
When the Protocol was established, it was meant to further clients’ interests in privacy and freedom of choice in connection with the movement of their registered reps. It served to lift some of the burden of a move, prevent immediate legal issues, and be less confusing for the end clients – as long as specific rules were followed. Under the Protocol, advisors are allowed to take five data points of client information at the time of resignation.
Simply being part of a Protocol transition does not create freedom.
There are still important guardrails that must be respected to avoid serious missteps:
- Permitted client information includes client names, addresses, phone numbers, emails, and account titles. No client account numbers, holdings, social security numbers, dates of birth, transaction history, or confidential notes and documents.
- At the time of resignation, a copy of all data take must be provided to the firm you are exiting from.
- Avoid solicitation before resignation. Any client conversations about “future plans” or “changes coming soon” before your formal resignation could violate both Protocol protections and your current employment agreements.
Critical Tips:
- No sensitive data: No SSNs, DOBs, account numbers, statements, etc. Stick to the guidelines.
- Organize Protocol data early: Prep the data in advance and have it ready in case the timeline moves.
- Craft your client message and practice it: Know what you want to say. Write it down. Practice it. Focus on client experience and relationship continuity.
PNA (Protocol Not Applicable) Transitions
“Protocol Not Applicable” refers to when the Protocol does not apply to the situation at all. It’s a term we made up at Advisor Transition Services, and we are trying to get it to stick. If you’re fortunate enough to operate under a PNA (Protocol Not Applicable) model — where you are already part of an independent firm and have ownership or rights to your client data, your transition could be more straightforward than the Protocol and non-protocol ones.
In a PNA transition, you generally have ownership of your client relationships and records. Which could mean that you’re entitled to export or download CRM data, client statement, account numbers, notes, billing information, client documents, etc. When the restrictions to data do not apply, the operational plan has a lot more flexibility.
The higher level of control grants you the ability to be proactive, rather than reactive.
You can prepare well in advance of your resignation by:
- Exporting and organizing your client data in secure, encrypted formats.
- Prepping your new custodian’s onboarding paperwork.
- Drafting detailed client communication materials.
- Setting up billing, reporting, and compliance systems in advance.
- Training your internal staff or virtual team on new processes and systems.
Critical Tips:
- Keep the focus on confidentiality: Just because you can take data doesn’t mean you should broadcast your plans to.
- Work closely with the new RIA’s compliance and operation teams: Prep paperwork, create templates, train on systems, understand processes and procedures.
- Prioritize client onboarding: Make the experience as seamless and personalized as possible.
In short, a PNA transition may give you a head start, but you still have to run the race with precision, confidentiality, and professionalism.
Final Thoughts: Know Your Category. Master Your Transition.
When advisors think about making a move, the first instinct is to look ahead — new firm, new custodian, new chapter. But the truth is, the small details matter. Success isn’t developed overnight. It’s built from the ground up, and you need to focus on how to start.
Identifying your transition type is more than just a compliance exercise — it’s the foundation of your entire strategy. Are you coming from a non-protocol firm, where you’re restricted from taking any client data? Does the Protocol apply and you’re allowed five basic categories of client information? Or is it a PNA (Protocol Not Applicable) situation, where you own your data and can prepare proactively?
Each type carries its own timeline, risks, and best practices — and each demands a different level of confidentiality, legal guidance, and operational planning. Failing to understand the nuances could result in lost clients, regulatory issues, or a stalled transition that costs you more than just time.
If you want your move to work — not just legally, but logistically and emotionally — you need to take the guesswork out of it.
At Advisor Transition Services, we don’t do one-size-fits-all. We work with financial advisors to build customized transition strategies that align with their transition type, unique book of business, and long-term goals. A transition isn’t just any event — it’s a launch – and it should be done right.
Make sure the next move you make isn’t just for change – but for an upgrade.
Stay Ahead!
