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FinCEN AML scope: Pennsylvania’s investment advisers

351 of Pennsylvania’s SEC-registered investment advisers clear FinCEN’s three-part AML scope test, from the SEC’s own roster dated 2026-10-02. See the exact filter and sources for how that population is defined.

What stands out in Pennsylvania

A median Pennsylvania firm manages $440.1 million, almost exactly the national median of $431.1 million, the closest match to the country's typical firm size of any state in this set. Where Pennsylvania stands apart is wrap fee programs: 11.7% of its firms participate in one, the highest share of the ten, against a 7.4% national rate. Its private-fund exposure runs the other way, at 24.5% against a national 39.9%.

Pennsylvania’s numbers, in full

Firms in scope
351
Median staff
7
Fewer than 20 people
300 (85.5%)
5 people or fewer
140 (39.9%)
Custody of client cash or securities
207 (59.0%)
A related person holds custody
92 (26.2%)
Advise at least one private fund
86 (24.5%)
Median AUM
$440.1 million

This page is independent research, not legal advice, computed from the SEC’s own public roster of investment advisers. See the method and sources. Verify anything load-bearing against the Federal Register text itself before acting on it. The custody figures above count roster disclosures only. Whether a qualified custodian’s own AML program covers the adviser is a separate question, answered on its own page.

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