Books and Records Checklist | Your RIA Compliance

Your Name:

Start Date:

Ending Date:

Applicable Month:

Applicable Year:

Are you firm's financial records kept current and accurate?

Yes

No

If a regulator requests the most recent month-end financial statements and you can easily procure them, you're good.

As a matter of practicality, we recommend that financial statements (balance sheet, etc.) be kept up no less than quarterly.

Indicate the month for which completed financial statements are available.

In most cases, "financial statements" mean a balance sheet prepared in accordance with generally accepted accounting principles, an income statement, a cash flow statement, and a net worth computation.

The month I selected for the previous question pertains to:

Current Year

Prior Year

For state-registered firms, have you maintained any other financial records that may be required?

Yes

No

Although largely uniform, some states may have nuanced requirements. If you maintain good accounting records and don't fall behind, this will, in most cases, take care of itself.

Have you maintained a copy of every executed advisory agreement with your clients?

Yes

No

We recommend maintaining a copy in a "client file" as well as a separate file containing all of your executed agreements.

Have you been maintaining or have you verified client information such as suitability or account records?

Yes

No

Note that the specific client information that is maintained, and where it is maintained, will vary between firms and, in some cases, jurisdictions.

Have you been maintaining or have you maintained trading records?

Yes

No

If you have ready access to trading activity via a custodian or other platform, you can select "Yes" without concern. However, we recommend a quarterly check at the minimum.

These trading records should include the terms and conditions of the trade and any instructions, modifications, or cancellations, the person at the firm who recommended the transaction, who placed the order, whether the trade was discretionary or non-discretionary, the account, the date of entry, and the broker-dealer used to execute the trade.

In most cases, the books and records requirement is five years. If, upon a regulator's request, you could easily find trading activity for the prior five years, you're good.

Have you maintained a record of brochure delivery (Form ADV Part 2A and 2Bs)?

Yes

No

If applicable, have you maintained a record of Form CRS delivery? This is not applicable to state-registered firms.

Yes

No

N/A

See our Form CRS Checklist if needed.

Other than your disclosed websites and social media, have you maintained a record of other advertising or marketing that the firm has conducted?

Yes

No

You can select "No" if there has been no other marketing.

If applicable, have you maintained the executed agreements between your firm and any third-party service provider?

Yes

No

N/A

If applicable, have you maintained documentation of client complaints or other matters pertaining to arbitrations or litigations in which the firm is involved?

Yes

No

N/A

Choose "NA" if there is nothing for the time period. It is recommended that, if such occurs, a separate file is maintained.

If applicable, have you maintained documentation of any performance calculations, such as formulas, data repositories, or other material used for the presentation of performance?

Yes

No

N/A

You can choose "not applicable" if you do not advertising or market performance and if your only presentation of performance is in one-on-one presentations or materials.

If applicable, have you maintained additional records that are required if you have custody?

Yes

No

N/A

If you do not have custody other than direct deduction of fees or other situations not requiring an accountant's audit, you should choose "not applicable."