Project Planning Checklist
Project Initiation
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.
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.
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.
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.
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.
Risk Management
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.
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.
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.
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.
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.
Budget and Resource Planning
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.
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.
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.
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.
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
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.
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.
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.
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.
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
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.
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.
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.
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.
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.
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.
