Expense Management Checklist
Monthly expense management cycle for an RIA or broker-dealer firm — covers T&E policy, employee submission, supervisor and compliance review, reimbursement, and books-and-records archiving. Run by the operations manager with CCO oversight on gift and entertainment items.
Policy and Compliance Setup
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Refresh the firm's T&E expense policy
Pull the current T&E policy from the compliance manual and confirm it still reflects current IRS per-diem rates, mileage rates, and the firm's expense categories. Material changes should be re-circulated to all employees with a fresh acknowledgment.
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Confirm FINRA Rule 3220 gift limits
Rule 3220 caps gifts to any single person at $100 per year in connection with the firm's business. Confirm the policy language matches and that the gift and entertainment log is the firm's system of record. Non-cash compensation under Rule 3221 is a separate carve-out.
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Map expense categories to GL accounts
Reconcile the categories used in Concur, Ramp, or Expensify with the firm's GL chart of accounts. Common gotcha: client-meeting meals coded as office expense, which distorts the entertainment line at year-end.
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Publish the policy to the firm intranet
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Document retention rules per SEC 204-2
Books and records under SEC Rule 204-2 (advisors) and FINRA Rule 4511 (BDs) require expense records be retained for at least five years, the first two in an easily accessible location. Confirm the archive location and retention rule on the document management system.
Expense Submission
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Submit expenses via Concur or Ramp
All submissions go through the firm's expense platform — paper or email submissions are not accepted. Reps using a corporate card should ensure card transactions are matched to the report before submitting.
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Attach itemized receipts to every line
Receipts must be itemized — a credit card slip showing only the total is not sufficient for meals or entertainment. The IRS substantiation rules and FINRA G&E rules both require the underlying detail.
Collects file -
Categorize each expense by type
The category drives the GL mapping and the compliance review path. Gift and entertainment items route to the CCO for the Rule 3220 check; other categories follow the standard supervisor flow.
Collects list -
Note business purpose and attendees
Per IRS substantiation, every meal or entertainment line needs the business purpose, names of attendees, and their relationship to the firm. "Lunch with client" is not sufficient — name the client and the topic discussed.
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Submit before the monthly cutoff
Reports submitted after the cutoff roll into the next reimbursement cycle. Late corporate-card transactions left unsubmitted past 60 days may be deducted from payroll under the firm's card agreement.
Review and Approval
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Supervisor reviews the report for accuracy
The direct supervisor confirms the business purpose is reasonable, totals tie to receipts, and no policy thresholds are exceeded without explanation. This is a substantive review, not a rubber stamp — supervisor sign-off is part of the FINRA Rule 3110 supervisory record.
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Run compliance review on G&E entries
Compliance pulls the gift and entertainment log year-to-date for each recipient and confirms the new entry doesn't push the per-recipient total over the $100 Rule 3220 limit. Tickets to sporting events, golf outings, and holiday gifts all count.
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Apply Rule 3220 gift limit check
For any gift or entertainment line, run the recipient through the firm's G&E log and confirm cumulative annual value stays under $100. Document the check on the report; if the limit is exceeded, the rep covers the overage personally and the item is returned NIGO.
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CCO signs off on flagged items
The CCO reviews any item flagged during compliance review — over-limit gifts, unusual vendor names, anything resembling a soft-dollar arrangement outside the 28(e) safe harbor. The decision and any reviewer notes become part of the books and records.
Collects list Collects paragraph Collects signature -
Return NIGO reports to the submitter
Reports that fail review go back to the submitter with specific remediation notes — missing itemization, missing attendees, or a Rule 3220 overage. Resubmission restarts the review window; track NIGO reasons to feed back into training.
Reimbursement and Payment
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Export approved reports to the GL
Push the approved batch from Concur or Ramp into QuickBooks, NetSuite, or the firm's GL. Confirm category-to-account mapping holds; spot-check one entry per category before posting.
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Process ACH reimbursement via payroll
Reimbursements run through the next payroll cycle as a non-taxable line per the firm's accountable plan. Verify each employee's bank-on-file matches what's in the payroll system before release.
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Notify the employee of payment date
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Reconcile corporate card statements
Tie the monthly corporate card statement to submitted reports line by line. Unmatched transactions over 60 days are escalated to the cardholder's manager; persistent gaps are a card-privilege issue.
Audit and Reporting
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Archive reports per SEC Rule 204-2
Push the month's approved reports, receipts, and review notes into the document management system (NetDocuments, Laserfiche, or equivalent) with a five-year retention tag. Confirm the archive is in WORM-compliant storage if the firm is BD-side.
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Run monthly expense variance analysis
Compare actual spend by category against the approved annual budget. Flag any category running more than 10% over plan and any individual rep whose spend has materially shifted month-over-month.
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Update the gift and entertainment log
Post all approved G&E line items into the running per-recipient annual log. The log is the firm's primary defense in a FINRA exam on Rule 3220; missing entries are a supervisory finding.
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Prepare quarterly expense report for the CCO
At quarter end, summarize total spend by category, NIGO rate, average review cycle time, and any G&E items that required CCO sign-off. The report goes into the compliance committee packet for the next meeting.
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