Project Planning Checklist
A planning workflow for advisory firms launching cross-functional projects — custodian transitions, CRM migrations, new service lines, or fee-schedule changes — that must clear compliance and survive a regulator exam. Run by a project lead with the CCO, COO, and operations on ...
Project Initiation
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Define the project scope and target outcomes
Write a one-page scope statement: what is in, what is out, and the success criteria. For projects touching client accounts (custodian transition, fee schedule change, model portfolio overhaul), name the AUM and account count affected so the executive sponsor sees the blast radius.
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Identify cross-functional stakeholders
Pull at minimum: the principal / executive sponsor, CCO, COO, advisor lead, CSA lead, and an IT/ops contact. For projects touching custodian or vendor systems (Schwab, Fidelity, Pershing, Orion, Tamarac, Wealthbox), add the relationship manager on the vendor side.
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Draft the business case
Cover projected revenue impact, advisor capacity unlocked, client experience improvement, and regulatory risk reduction. Include a do-nothing alternative — partners reject business cases that don't compare against the status quo.
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Assemble the project team and name an exec sponsor
Name a single accountable lead (RACI: A) and a partner-level sponsor with budget authority. Distinguish full-time project resources from part-time SMEs so backfill conversations happen up front.
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Build the project roadmap with regulatory milestones
Plot dependencies against fixed regulatory dates: Form ADV annual filing window, fiscal year end, surprise custody exam, SOC 2 audit. Avoid go-live during a known exam period or annual ADV brochure delivery cycle.
Collects file
Risk Management
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Catalog operational and regulatory risks
Cover the standard categories: client communication failure, books-and-records gap, off-channel comms exposure, custody-rule trip, fee-billing error, AML/CIP regression, vendor outage, and key-person dependency. The 2022-2024 SEC enforcement actions on off-channel communications are a useful benchmark for severity.
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Score each risk for likelihood and client impact
Use a 1-5 likelihood and 1-5 impact scale. Anything scoring 4+ on impact gets named mitigation regardless of likelihood — high-impact / low-probability events are the ones that show up in regulator findings.
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Draft mitigation plans for top risks
For each top risk, document the control, the trigger that requires escalation, and the rollback plan. Custodian or vendor cutover projects need an explicit rollback window — the moment past which you cannot revert without client harm.
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Assign risk owners across compliance and ops
Each risk gets one named owner (not a team). Compliance owns regulatory items; COO owns operational; CCO retains oversight. Avoid the common pattern of leaving every risk owned by the project lead — that's a single point of failure.
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Establish the risk register and review cadence
Weekly review during active phases; monthly at steady state. The register feeds the next CCO compliance committee meeting and is part of the books-and-records retention for the project.
Collects file
Budget and Resource Planning
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Build the project budget with vendor and tech costs
Include one-time implementation fees, ongoing license costs, data-conversion costs, training, and a 15-20% contingency. For custodian transitions, factor in the ACATS volume cost and any termination fees on the outgoing platform.
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Secure principal approval for project spend
Present the budget to the partner group or executive committee. Capture the approval decision in writing — verbal sign-off doesn't survive a partner-turnover or audit-trail question six months later.
Collects list -
Allocate FTE across advisors, ops, and CSAs
Estimate hours per role per week. Advisor time is the most expensive and most easily under-budgeted — in transitions, advisors typically need 4-8 hours per week for client communication on top of normal book duties.
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Document the resource and backfill plan
Identify which BAU tasks get paused, redistributed, or backfilled by contractors during the project. CSA capacity is a common bottleneck — quarterly performance reporting and RMD chase calendars don't pause for projects.
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Set up monthly budget burn tracking
Track committed vs. forecast vs. actual on a single page. Flag variance over 10% to the sponsor before the next monthly review, not at quarter end.
Compliance and Regulatory Review
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Map applicable SEC, FINRA, and state rules
Cover the relevant rules for the project: Advisers Act 204-2 (books and records), 206(4)-1 (advertising), 206(4)-7 (compliance program), Reg S-P (privacy), Reg BI / Form CRS if BD-side, and applicable state notice filings. Don't rely on the prior project's mapping — rule sets change.
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Determine whether an ADV amendment is required
Material changes to services, fees, custodian relationships, conflicts, or disciplinary disclosures trigger an other-than-annual amendment within prompt timelines. When in doubt, treat as material — amending unnecessarily is cheap; missing a required amendment is an exam finding.
Collects list -
File the ADV amendment via IARD
File through IARD; deliver the updated brochure to existing clients per the firm's policy. Keep the redline showing what changed and the cover memo from the CCO documenting the rationale — both belong in the books-and-records file for this project.
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Draft the project compliance plan with the CCO
Cover client disclosure language, supervisory review touchpoints, advertising / communication review for any rep-facing or client-facing material, and the books-and-records retention plan for project artifacts.
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Schedule pre-launch CCO sign-off
CCO review must be calendared at least 5 business days before go-live. Walking the CCO through the launch the day before is the most common reason a launch slips — leave runway for findings.
Quality Assurance and Launch
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Define acceptance criteria for go-live
Write specific, testable criteria: e.g., performance reports tie to custodian holdings within $1, fee billing reconciles three ways, all advisor logins authenticated. Vague criteria like 'system works correctly' fail the first audit.
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Build the UAT plan with advisor and CSA scenarios
Include real workflows: open a new IRA, run a quarterly fee billing cycle, generate a client performance report, process an ACATS, run an OFAC screen on a related party. Test the failure paths, not just the happy path.
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Run UAT with the advisor and ops teams
Schedule 2-3 UAT sessions with sample client data (synthetic or pseudonymized — do not test against real client PII unless the test environment has the same controls). Capture defects in the project tracker with severity and owner.
Collects list -
Document the remediation plan for failed cases
For each failed scenario, capture root cause, fix owner, retest date, and a revised go-live decision. Do not push to launch with open critical defects — the cost of post-launch remediation on client-facing systems is much higher than a slipped date.
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Conduct the final go / no-go review
Sponsor, CCO, COO, and project lead present in the room (or on the call). Decision is binary: launch or hold. Capture the signed sign-off and any conditions; this is the artifact a regulator will ask for if anything goes wrong post-launch.
Collects list Collects paragraph Collects signature -
Capture lessons learned for the next project
Hold a 60-minute retro within two weeks of go-live. Capture what to keep, what to change, and three concrete improvements for the next project's checklist. Lessons captured later than this are usually wrong — memory degrades fast.
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