A Referral Path for Self-Employed Prospects Below Your Minimum

The prospect you turn away every week

An adviser with a $500,000 or $1 million minimum meets this person constantly: a self-employed consultant, a contract physician, a software developer between full-time jobs, a rideshare driver with a second business. They have real income, sometimes six figures, but little accumulated in investable assets, and their most pressing need is not portfolio management. It is figuring out how much they can put into what account, by when, and how to keep track of it.

MBO Partners counted 5.6 million independents earning $100,000 or more in 2025, up 19 percent in a year and 86 percent since 2020 (https://www.mbopartners.com/blog/press/2025-state-of-independence-reveals-growing-talent-strategy-for-business). Most of them are below your minimum today and will not be in ten years. Turning them away with a polite email loses the relationship. Taking them on unprofitably loses money. A structured referral to a subscription retirement app is the third option, and the Gigaverse adviser partner program is designed to be that path.

What the prospect actually needs in year one

Before deciding where to send them, be clear about what they need. For a self-employed person under your minimum, the checklist is short and mostly not investment advice:

• •A contribution plan. Roth IRA at $7,500 for 2026, or a Solo 401(k) with a $24,500 employee deferral plus roughly 20 percent of net self-employment earnings as an employer contribution, up to $72,000 total ($80,000 at 50 and older). A SEP if they missed the December 31 deferral election.
• •A running estimate of net earnings, because every one of those limits is computed from net Schedule C profit after expenses and half of self-employment tax, not from gross.
• •Deadlines, particularly the December 31 written election for Solo 401(k) deferrals.
• •A hand-off to their CPA at filing time.
• •A simple, low-cost investment default they will not tinker with.

A subscription app that does the first four and routes the fifth through a broker-dealer covers year one. Your firm covers years five through thirty.

The three ways a referral can be structured

Uncompensated. You give the prospect the name and walk away. No Marketing Rule promoter obligations attach, though if you have any business relationship with the provider your Form ADV should say so.

Compensated by the provider. You receive something for the referral. You are now a promoter under Rule 206(4)-1 and the provider is the adviser bound by the rule. The prospect must receive a disclosure that you were compensated, the material terms, and the conflict it creates. Above $1,000 in twelve months, there must be a written agreement. Your own fiduciary duty and Form ADV Item 14 independently require conflict disclosure. Some states treat paid solicitors as investment adviser representatives who must register.

Compensated by the client. You charge a flat planning fee to set up the contribution plan yourself and then point them to a tool for execution. Cleanest of all, but many advisers find the fee too small to justify the compliance overhead of a planning-only engagement.

Why the form of compensation is not up for negotiation

Advisers sometimes ask whether the provider can pay a small share of the assets referred, or a fee per funded account. A responsible provider will say no, and it is worth understanding why so the answer does not read as stinginess.

A payment that varies with whether the prospect opens a brokerage account or deposits money into it resembles transaction-based compensation. Exchange Act Section 15(a) requires anyone receiving such compensation for effecting securities transactions to be a registered broker-dealer, and FINRA Rule 2040 bars member firms from paying it to unregistered persons. A share of advisory fees, whether expressed as basis points or a percentage of AUM, is a fee split, and an SEC-registered adviser cannot split fees with someone who is not registered or supervised as an adviser representative.

Gigaverse, which is pursuing SEC RIA registration, pays advisers in exactly two ways: a share of revenue from paid app subscriptions, or a flat per-seat licence fee if your firm buys seats for clients. Nothing is paid per account, per deposit, per enrollee, or on assets. Every adviser partner signs a Marketing Rule written agreement, delivers the promoter disclosure Gigaverse supplies, and must disclose the conflict of interest to the referred client. The how we make money page says the same thing to the client.

A referral workflow that fits in an existing practice

• •Screen. Prospect is self-employed, below minimum, primary need is a contribution plan and account.
• •Disclose. Deliver the promoter disclosure and your own conflict statement in writing, at the time of the referral. Keep a copy.
• •Refer. Give the prospect the link. They subscribe or they do not.
• •Document. Note the suitability reasoning in your CRM: why an app was appropriate rather than your services.
• •Calendar. Set a review for two to three years out. Many of these prospects will cross your minimum, and the Roth IRA held at the broker-dealer transfers by ACATS like any other account.
• •Report. Log compensation received for Form ADV Item 14 and your annual compliance review.

What to tell the prospect

"You do not need a portfolio manager yet. What you need this year is to set up the right account, contribute the right amount, and not miss the December deadline. I am going to refer you to Gigaverse, a subscription app for self-employed people that does exactly that. If you pay for the app, my firm receives a share of your subscription. We receive nothing based on your contributions or balance. That is a conflict of interest and you should weigh it. When your assets grow, come back and we will talk about working together directly."

The prospect can check the contribution math with the free Gigaverse tools before subscribing. If their income is low enough, they will also see how the federal Saver's Match, starting January 1, 2027, pays up to $1,000 into a non-Roth IRA even when the qualifying contribution went into a Roth; the Saver's Match Roth rule page explains it.

Where Gigaverse fits

Gigaverse is a subscription retirement app for 1099 workers. Today it offers a Roth IRA through a FINRA/SIPC-member broker-dealer, and Solo 401(k) and SEP IRA applications are open, with the math, tracking and CPA hand-off provided throughout. It is pursuing SEC RIA registration and does not guarantee returns. Adviser partners are paid only a share of subscription revenue or a flat per-seat licence, sign a Marketing Rule agreement, and disclose the conflict to every referred client. The program terms are on the adviser partner page.