Who is the FinTech service built for?

This service is built for fintech entrants, startups, and technology-first firms entering regulated financial markets.

What kind of help does GiGCXOs provide to fintech firms?

GiGCXOs helps fintech firms with regulatory strategy, compliance infrastructure, and practical guidance so compliance is built into the business from day one.

Can fintech firms use GiGCXOs before launch?

Yes. GiGCXOs positions this offering for firms entering regulated markets, making it useful during early planning and launch stages.

Does GiGCXOs support growing fintech firms after launch?

Yes. The service is designed to support firms as they build, scale, and adapt their compliance operations in regulated markets.

FinTech Compliance Consulting

Choosing Your Path

Broker-Dealer, RIA, or CFTC/NFA? It Depends on What Your Platform Does

The distinction comes down to what your platform actually does: execute securities transactions, provide investment advice for a fee, or intermediate commodities, futures, prediction market, or swaps activity. Many FinTech companies fit one lane. Some span two or even all three.

Broker-Dealer Path

You Execute Trades, Handle Orders, or Operate a Trading Platform

Any platform that enables customers to buy or sell securities — stocks, ETFs, bonds, options, or tokenized assets — is likely engaging in broker-dealer activity. Registration with FINRA and the SEC is required before you go live. Operating without it is a federal violation.

Retail trading apps — commission-free stock or ETF platforms (think Robinhood model)

Embedded brokerage — neobanks or super-apps adding stock trading to a banking product

B2B brokerage infrastructure — "brokerage as a service" APIs sold to other apps

Alternative trading systems (ATS) — private matching platforms for securities

Fractional share platforms — enabling micro-investing in whole securities

Private market platforms — facilitating secondary trading in private company stock

RIA Path

You Provide Investment Advice, Manage Portfolios, or Automate Financial Guidance

Any platform that gives personalized investment advice for compensation — or that automatically manages a customer's portfolio on their behalf — is likely providing investment advisory services. This requires registration as an RIA with the SEC or state regulators, and compliance with the fiduciary standard under the Advisers Act.

Robo-advisers — automated portfolio construction, rebalancing, and tax-loss harvesting

Financial planning apps — subscription-based advice platforms with personalized recommendations

Goal-based investing platforms — retirement, education, or wealth-building automation tools

Real estate investment platforms — REITs or fund structures requiring advisory registration

AI-powered financial advisers — LLM-based platforms giving personalized financial guidance

ESG / thematic investing platforms — curated portfolio strategies based on client values

CFTC / NFA Path

You Facilitate Commodities, Futures, Swaps, or Event Contracts

Any platform that offers commodity interests, futures, swaps, or prediction market style event contracts can trigger CFTC and NFA obligations. Registration may involve an IB, FCM, SEF, DCM, or related commodity framework depending on how the product is structured and who the users are.

Commodities trading apps — retail access to metals, energy, or other commodity-linked products

Futures and swaps platforms — routing or matching derivatives activity for US persons

Prediction market products — event contracts with CEA and Part 40 implications

Commodity-linked yield or structured products — where swaps analysis matters from the start

Decision Framework

Six Questions That Determine Your Registration Path

In practice, the BD vs. RIA vs. CFTC/NFA question is more nuanced than it appears. Here are the key factors that drive the analysis — and what each answer implies for your compliance roadmap.

Question 01

Do customers place buy/sell orders on your platform?

BD Yes — platform accepts and routes orders

RIA No — we make decisions on their behalf

CFTC Orders relate to commodities, futures, swaps, or event contracts

Question 02

Do you charge a commission, spread, or per-trade fee?

BD Yes — transaction-based revenue

RIA No — AUM-based or subscription fee

CFTC Spread, execution, clearing, or contract-based derivatives revenue

Question 03

Does your platform hold customer securities or cash?

BD Yes — custody of assets (Rule 15c3-3 applies)

RIA Via qualified custodian only (Rule 206(4)-2)

CFTC Customer margin, collateral, or segregated commodity funds

Question 04

Do you give personalized recommendations for a fee?

RIA Yes — fiduciary standard applies

BD Incidental to transactions — Reg BI applies

CFTC Product design may still trigger commodity pool, CTA, or swaps analysis

Question 05

Does your algorithm automatically rebalance or trade?

RIA Yes — discretionary management = advisory

BD Only when customer initiates

Multi Automated trading + advice + derivatives can trigger overlapping regimes

Question 06

Are you white-labeling brokerage services to other apps?

BD Yes — the underlying BD must be registered

RIA If providing advisory services to those apps

CFTC Commodity execution or clearing infrastructure may need NFA/CFTC registration

CFTC / NFA Registration

Commodities, Futures, Prediction Markets, and Swaps Need Their Own Compliance Architecture

FinTech firms entering commodity and derivatives markets face a different supervisory model than securities firms. The product design, counterparty structure, customer onboarding, margin handling, and NFA obligations all need to be mapped before launch.

IB, FCM, SEF, or DCM — Which Structure Fits?

We map your platform to the correct CFTC/NFA registration path based on whether you introduce orders, accept customer funds, facilitate swaps execution, or list event contracts. That analysis drives the entire compliance build.

IB / FCM SEF / DCM NFA Strategy

Prediction Markets and Event Contracts

Prediction market products require careful review under the Commodity Exchange Act, CFTC Part 40, and related no-action and product certification frameworks. We help structure the product before it creates enforcement risk.

Part 40 Event Contracts Product Review

Customer Margin, AML, and NFA Exams

Commodity and futures businesses need procedures for customer funds, disclosures, margin, books and records, AML, and NFA examination readiness. We build those programs to match how your platform actually operates.

Customer Funds AML / BSA NFA Exams

Swaps and Commodity Product Structuring

We assess whether your yield, leverage, derivative, or synthetic exposure product could be viewed as a swap, futures contract, or other regulated commodity interest, then design the documentation and controls around that conclusion.

Swaps Analysis Product Structuring CEA Mapping

Broker-Dealer Registration

Building a FinTech Broker-Dealer from the Ground Up

For FinTech companies that need broker-dealer registration, speed and precision matter. A delayed FINRA approval costs runway. A compliance program that doesn't fit your tech stack creates operational drag from day one. GiGCXOs designs both to fit your business.

Regulatory Strategy & Business Model Review

Before filing, we map your exact product to the regulatory framework — what activities trigger broker-dealer status, which FINRA rules apply to your tech stack, whether you need an ATS or a traditional BD, and whether a correspondent or introducing relationship is a faster path to market than direct FINRA membership.

Weeks 1–3

Entity Setup & Capitalization

We advise on entity structure, state selection, net capital requirements (Rule 15c3-1), and FOCUS Report obligations. FinTech BDs often use technology to lower operational costs — we design your capital structure to take advantage of that. We also prepare your principal licensing plan (Series 7, 24, 27/28 as needed).

Weeks 2–5

FINRA New Member Application

We prepare and submit your NMA — Form BD, business plan, compliance manual, WSPs, financial projections, technology risk assessment, and background disclosure for all associated persons. We shepherd your application through FINRA's review process and prepare your team for the NMA interview.

Weeks 4–12

Launch Readiness & Ongoing Compliance

Post-approval, we provide fractional CCO or compliance officer coverage, annual certifications, FINRA exam preparation, WSP updates, Reg BI implementation review, AML program management, and state blue-sky registrations. For technology-driven BDs, we integrate AICompliance360 to automate surveillance and reporting.

Ongoing

RIA Registration

Becoming a Registered Investment Adviser — Built for FinTech

RIA registration is generally faster and less capital-intensive than broker-dealer registration — but the compliance program for a FinTech RIA is anything but simple. Algorithmic advice, data-driven recommendations, and automated portfolio management all carry distinct disclosure, conflict-of-interest, and fiduciary obligations that most traditional compliance programs aren't built to handle.

SEC vs. State Registration — Which Applies to You?

RIAs with $110M or more in AUM register with the SEC. Below that threshold, state registration is required in each state where you have clients. FinTech platforms often cross state lines immediately — we design your registration structure to be scalable from day one, with a clear plan to transition from state to SEC registration as you grow.

Form ADV State Registrations AUM Threshold Planning

Robo-Adviser Compliance — Algorithmic Fiduciary Obligations

Robo-advisers are held to the same fiduciary standard as human advisers — but the SEC's guidance on algorithmic advice creates specific disclosure requirements around how recommendations are generated, what data is used, and how conflicts of interest are managed. We build your disclosure framework and compliance program around these requirements from the start.

Algorithm Disclosure Conflict of Interest Reg BI vs. Fiduciary

Investment Advisory Agreement & Fee Structure

Your client agreement and fee structure must satisfy the Advisers Act and be reflected accurately in your Form ADV Part 2 (the "brochure"). We draft your investment advisory agreement, ensure your fee schedule complies with SEC guidance on AUM-based, flat, and subscription fees, and coordinate disclosures around performance fees if applicable.

Form ADV Part 2 Fee Disclosure Performance Fees

Custody & Books and Records for FinTech RIAs

Most FinTech RIAs use third-party qualified custodians (Schwab, Fidelity, Apex) and don't take custody directly. We design your custody arrangements to satisfy Rule 206(4)-2, implement the books and records program required under Rule 204-2, and prepare for SEC examination with documentation that reflects your technology-driven model.

Qualified Custodian Books &amp;amp; Records Exam Readiness

Dual Registration

Some FinTech Platforms Span Multiple Frameworks — and That's Where Things Get Complex

Full-service FinTech platforms may execute securities transactions, provide advisory services, and facilitate commodity or derivatives activity inside the same product ecosystem. That multi-framework structure has specific regulatory implications that require careful program design.

Switching Hats Across Multiple Regimes

A firm operating across broker-dealer, investment adviser, and commodity frameworks must clearly define, document, and disclose which regulatory hat it is wearing during each interaction. GiGCXOs designs the supervisory framework and disclosure program to manage those transitions.

Example: Full-Service Wealth Platform

A platform that lets customers open a self-directed brokerage account and also enroll in a managed portfolio program may need both BD and RIA registrations. Common in FinTech companies building comprehensive wealth products.

Example: AI Advice + Execution + Derivatives

A platform using AI to give personalized advice, routing the resulting securities trades, and offering commodity or event-contract exposure can cross all three regimes at once. The AI component adds algorithmic disclosure obligations on top of the registration analysis.

Why GiGCXOs

FinTech Compliance That Moves at the Speed of Your Product

Traditional compliance firms are built for traditional financial firms. GiGCXOs is built for companies where technology is the product — where compliance needs to integrate with engineering sprints, product roadmaps, and investor timelines, not work against them.

We Cover All Three Regulatory Lanes

GiGCXOs provides compliance experts across all three categories: SEC/FINRA for broker-dealers, SEC/state for investment advisers, and CFTC/NFA for commodities, futures, prediction markets, and swaps. That means we can give you an objective recommendation on your registration path, not one shaped by a narrower practice area.

Built for Technology-Driven Business Models

Algorithmic trading, AI-powered advice, embedded finance, white-label brokerage, and API-first platforms all have compliance implications that traditional WSP templates don't cover. We write compliance programs from scratch to match how your technology actually works — not how a legacy compliance manual assumes it works.

AICompliance360 — Compliance Infrastructure at Scale

Through our AI-powered compliance platform, FinTech companies can deploy automated trade surveillance, real-time supervisory alerts, regulatory filing generation, and exam-ready documentation — at a fraction of the cost of building an in-house compliance team. Ideal for pre-revenue or seed-stage companies managing burn.

Fractional CCO Coverage from Day One

Broker-dealers, SEC/state advisers, and CFTC/NFA-regulated firms all need accountable compliance leadership. GiGCXOs provides fractional CCO and principal-level coverage from professionals who have served in those roles inside fast-moving FinTech environments.

Investor-Ready Compliance Programs

Institutional investors and strategic partners conduct compliance due diligence before investing in or partnering with regulated FinTech firms. GiGCXOs designs programs that satisfy regulatory requirements and hold up to sophisticated investor scrutiny — so your compliance program becomes a competitive advantage, not a liability.

Full Registration to Ongoing Exam Support

We don't disappear after registration. GiGCXOs provides end-to-end support through the full compliance lifecycle — initial registration, ongoing regulatory updates, WSP amendments as your product evolves, FINRA and SEC examination support, and escalation management for any regulatory inquiries or investigations.

Services for FinTech Firms

Everything You Need, in One Partner

Broker-Dealer Registration (Full Service)

End-to-end FINRA NMA management. Entity formation, Form BD, compliance manual, WSPs, background checks, financial projections, and FINRA interview prep. Average 90-day completion for technology-first applicants.

RIA Registration (SEC & State)

Complete Form ADV preparation, investment advisory agreement drafting, compliance manual design, state registration filings, and IARD submission. Scalable structure built for platform growth.

CFTC / NFA Registration for Commodities, Futures, and Swaps

Registration strategy for IB, FCM, SEF, DCM, and related commodity pathways. Includes product mapping, NFA documentation, supervisory procedures, AML design, and ongoing examination support.

Robo-Adviser & Algorithmic Advice Compliance

Compliance program design specifically for algorithmic and AI-driven advisory products — including algorithm disclosure documentation, conflict-of-interest analysis, backtesting disclosure, and suitability/fiduciary mapping.

Multi-Framework Program Design

For platforms operating across BD, RIA, and CFTC/NFA categories — supervisory framework design, "switching hats" disclosure program, unified compliance manual design, and coordinated examination support.

Embedded Finance & White-Label Compliance

For FinTech companies building brokerage-as-a-service or advisory-as-a-service products: regulatory analysis of your distribution model, BD agreement review, correspondent/introducing BD structuring, and downstream compliance program oversight.

AICompliance360 — Automated Compliance Platform

Continuous trade surveillance, automated regulatory filing generation, real-time supervisory alerts, and exam-ready documentation — powered by AI and built specifically for technology-first financial firms managing compliance at scale.

The Right Regulatory Path for Your FinTech Business