Advisor and Employee Onboarding Checklist

Determine whether the role requires FINRA registration (Series 7, 24), state IAR registration (Series 65 or 66), dual registration, or none. Capture the classification before ordering fingerprints — registered roles need Form U4 and fingerprint cards on a different timeline than unregistered ops or banking hires.

Search BrokerCheck (FINRA) and IAPD (SEC) for prior CRD history, U4 disclosures, and customer complaints. Save the PDFs to the candidate file — exam staff will ask whether the firm reviewed these before extending the offer.

Submit fingerprint cards through FINRA Gateway for any registered role; run an FCRA-compliant background check (criminal, credit, education, prior employment). Capture written candidate consent before initiating — FCRA adverse-action procedures apply if the report drives a no-hire.

Review for criminal disclosures, financial events (bankruptcies, liens, judgments), regulatory actions, and customer complaints. Anything reportable on Form U4 questions 14A through 14M needs CCO review before the U4 is filed — late-discovered disclosures are a frequent FINRA exam finding.

The CCO documents whether to proceed, decline, or impose heightened supervision (Rule 3170 Taping Rule consideration if the rep comes from a disciplined firm). Save the determination memo to the candidate file before the offer is finalized.

Send via DocuSign with offer letter, restrictive covenant (non-solicit / Protocol for Broker Recruiting status), and acknowledgment of compliance manual. Confirm the candidate is not subject to a non-compete from the prior firm before the start date.

U4 must be filed and approved before the rep transacts in a registered capacity. Attach all disclosure DRPs (Disclosure Reporting Pages) supported by the CCO determination memo. Register every state where the rep will solicit business — failing to register a state of activity is one of the most common state-exam findings.

Verify exam dates in CRD; confirm CE status (Regulatory Element due within 120 days of birthday, Firm Element annual). If the rep has been out of the industry more than two years, schedule the requalification exam or apply for the MQP (Maintaining Qualifications Program) extension.

Draft the brochure supplement covering education, business background (last five years), disciplinary information, and supervision. Existing advisory clients receiving services from this IAR get the supplement at first contact.

State IAR registration via IARD; pay state fees; track de minimis exemptions (typically 5 retail clients per state in 12 months) where the rep does not register. Bookmark the renewal calendar — state renewals run on a December cycle.

Image the laptop with full-disk encryption, EDR agent, and DLP. Enroll the user in MFA (Duo, Okta, or Microsoft Authenticator) for email, custodian portals, and CRM. No bring-your-own-device for client communications.

Add the new mailbox to the journaling rule before the rep sends the first client message. Also enroll in compliant texting (MyRepChat or Hearsay Relate) and disable iMessage / WhatsApp for client contact — off-channel comms have driven $2B+ in SEC penalties since 2022.

Grant role-based access in the CRM, financial planning tool (eMoney, RightCapital, MoneyGuidePro), risk profiling (Riskalyze / Nitrogen), and the custodian portal (Schwab Advisor Center, Fidelity Wealthscape, Altruist). Confirm the rep does not have access to client households outside their book.

Cover CIP, CDD, beneficial ownership (25% rule), OFAC SDN screening, CTR thresholds, and SAR escalation procedures (30-day filing deadline from detection of suspicion). New hires get this within the first week, not at the next annual cycle.

Required under Rule 204A-1 for IARs. Capture initial holdings report (within 10 days of hire, current within 45 days), pre-clearance procedures for reportable securities, and quarterly transaction reports. Walk through the firm's restricted list and watch list.

Cover the Identity Theft Red Flags program, the 2024 Reg S-P amendments (30-day breach notification), and the wire-fraud verbal verification policy. Reps must call back the client at a known number for any wire instruction change — no exceptions.

Train on the four obligations (Disclosure, Care, Conflict, Compliance) and the documentation expected for each retail recommendation. Reinforce that Form CRS is delivered at first recommendation, new account, or new service — not just at engagement.

Per Rule 204A-1, the holdings report is due within 10 days of becoming an access person and must be current as of a date within 45 days prior. Submit through ComplySci, MyComplianceOffice, or the firm's manual log.

Mentor is a senior advisor or operations lead — not the direct supervisor. Set a weekly 30-minute cadence for the first 90 days covering case review, client-facing language, and questions the new hire would not ask the supervisor.

One discovery meeting (new prospect) and one quarterly review (existing household). Debrief afterward — how the advisor handled fee discussion, how the planning software was driven live, how risk tolerance was framed.

Confirm all training modules complete, U4 amendments current, personal trading attestation submitted, and CRM data hygiene on assigned households. Surface any blockers — missing custodian access is the most common finding at 30 days.

Final review covers compliance training completion, supervisory observations, any heightened-supervision conditions, and CE plan for the calendar year. CCO signs off before the rep moves to standard supervisory cadence.