Annual Client Review Checklist

Open the household record in Wealthbox / Redtail / Salesforce FSC. Confirm the last review date, open service items, and any flags (RMD client, complex tax, concentrated position, EDD/PEP). The CSA preps the packet; the advisor signs off before the meeting is scheduled.

Run the household report in Black Diamond, Orion, Tamarac, or Addepar through the prior month-end. Include time-weighted returns net of fees, benchmark comparison, and current allocation vs. model with drift percentages by sleeve.

Re-run the Monte Carlo with current balances, contributions, and any goal changes from last year. Note any drop in probability of success below the firm's 75% threshold so the advisor can address it in the meeting.

Confirm primary residence, mailing address, phone, and email match what's on file with the custodian. State-of-residence changes can trigger IAR registration requirements — flag any move to the CCO.

Capture changes in employer, retirement date, marriage/divorce, new dependents, or inheritances. Each of these is a planning trigger — divorce reshapes beneficiaries, retirement triggers Social Security and Medicare/IRMAA planning, new dependents change 529 and life insurance needs.

Run the client, joint owner, trustees, and any 25%+ beneficial owners through Refinitiv World-Check, LexisNexis Bridger, or the firm's AML tool. Document the screen date and result in the file even when clear — exam staff want to see the recurring evidence.

Have the client retake the Riskalyze / Nitrogen, Tolerisk, or FinaMetrica questionnaire. Compare the new risk score to the prior year and to the current portfolio allocation. A score drop of 10+ points usually justifies a model change, not just a rebalance.

Compare each sleeve to its target band. Flag any position outside the firm's 5% (asset class) or 3% (sleeve) tolerance for rebalance in iRebal, Tamarac, or Eclipse. Note tax lots before trading — short-term gains and wash-sale windows should be checked, not assumed.

Run the tax-loss scan in Holistiplan or the rebalancer's TLH module. Confirm no wash-sale violation across the household — including the spouse's IRA, which is the most-missed disallowance. For taxable accounts only; never harvest in IRAs.

Write the Reg BI / fiduciary rationale in the CRM: why this model, why not the prior model, what alternatives were considered, costs and conflicts disclosed. Exam staff pull this narrative for retail recommendations — a checkbox without the why fails.

For clients age 73+ (SECURE 2.0), confirm current-year RMD is calculated and on track for Dec 31. Inherited IRAs follow the 10-year rule with annual distributions when the decedent was already in pay status. Missing an RMD triggers a 25% excise tax — chase by early Q4 if not yet taken.

Submit the distribution request at the custodian with withholding elections confirmed by the client in writing. For QCDs, route the check directly to the qualified charity from the IRA — never deposit to the client first.

Verify the annual brochure offer (or delivery on material change) was sent within 120 days of fiscal year-end. Skipped delivery is a routine SEC exam citation. Capture the delivery date and method in the compliance log.

If a new account type, service, or rollover recommendation is made at this review, Form CRS must be delivered at recommendation time. Retain the acknowledgment in the client folder.

Walk through primary and contingent beneficiaries on each IRA, Roth, 401(k) rollover, annuity, and TOD account. The most common gap is a stale ex-spouse beneficiary after a divorce — confirm explicitly, don't assume. File the signed custodian beneficiary forms.

Send the screening hit, supporting documents, and any client explanation to the CCO. The CCO determines whether enhanced due diligence, account restriction, or a SAR is required. Do not transact on the account until the CCO clears it.

The CCO (or designated reviewer) confirms the file contains: refreshed KYC, OFAC screen evidence, current risk profile, recommendation rationale, ADV/CRS delivery records, and updated beneficiary forms. This is the supervisory review the SEC pulls during a routine exam.

Email the client a recap covering decisions made, allocation changes, planning updates, and items requiring their signature. Send through the firm's archived email system — never personal Gmail. Off-channel comms are the most-fined deficiency of the past three years.

Set the next review on the CRM service calendar, plus any interim touchpoints (mid-year check-in, tax planning call in Q4, RMD chase in October). Tag the household for any segment-specific cadence the firm runs.