Project Closure Checklist

Pull actuals from the GL cost center and tie them back to the approved project budget. Account for accruals on services rendered but not yet invoiced — common gaps are the final month of consulting fees and post-go-live custodian implementation charges.

Check AP for any open POs tied to the project. Anything still in flight should either be paid before closure or moved to an accrual with a documented receipt date so it doesn't surface in next quarter's variance reporting.

Compare actuals to budget by category. Anything over the firm's 5% materiality threshold needs a written explanation — scope change, vendor overrun, exchange-rate movement, or contingency draw — with a reference to the approving change order.

For material variances, write a short memo with the cause, the dollar impact, and what the firm is changing in future project intake or estimating to prevent recurrence. CFO sign-off closes the variance.

If any project costs flowed through to client billing — implementation charges, custodian transition fees — three-way reconcile the invoice, the custodian fee debit, and the internal calculation before the final close.

Cover scope delivered vs. planned, schedule and budget performance, KPIs against baseline, and open risks transitioning to BAU. Keep it tight — three to five pages with appendices for detail. The steering committee reads the summary; auditors read the appendices.

Walk the steering committee through outcomes, residual risk, and the hypercare plan. Capture decisions in the meeting minutes — they go into the project record alongside the final report.

SEC Rule 204-2 requires advisory firms to retain books and records for five years (first two years on-site, easily accessible). Project artifacts that touched advisory operations — vendor due diligence, custodian transition records, advice-impacting system changes — get the same retention treatment. File in NetDocuments or your archive of record with the right retention class applied.

Final executed copies — MSA, SOW, change orders, DPAs — go into the contracts repository indexed by counterparty and renewal date. The legal team will reference these for any post-closure dispute or audit pull.

If the project moved or copied client NPI — custodian conversions, CRM migrations, performance reporting cutover — confirm source data is purged from staging environments and any vendor-held copies have been certified destroyed per the DPA. Reg S-P enforcement has accelerated; staging-environment NPI is a recurring finding.

The CCO confirms the project's compliance posture at closure: regulatory requirements addressed, books-and-records archival complete, residual issues entered on the open-items log. This memo is the durable record an SEC examiner will ask for.

If any project contractors were registered through the firm — IARs, registered reps with Series 6/7/63/65/66 — their CRD registrations must be terminated when the engagement ends. Independent contractors with no firm registration don't trigger this.

FINRA requires Form U5 filing within 30 days of termination. Late filings draw penalties and follow the rep on their record. Coordinate with HR so the termination date and reason match payroll and the CRD entry exactly.

Update the resource planner so allocations roll off and team members show available capacity for next-quarter project intake. A common slip is leaving allocations in place after go-live, which masks utilization for two months.

Walk through the access matrix: custodian portal, CRM, performance reporting, archiving system, file shares, VPN, MFA tokens. Disable rather than delete so audit logs remain intact. SEC and FINRA exams pull access logs — orphaned accounts are a recurring finding.

Coordinate device return with IT for remote workers — pre-paid shipping label, chain-of-custody log, certificate of wipe before reissue. Any device that may have held client NPI gets the formal wipe procedure, not a quick reformat.

Run a 60-90 minute retro with the working team — what worked, what hurt, what to change. Keep it blameless and concrete. Anchor the conversation to the variance memo and any open risks so the takeaways tie to evidence, not vibes.

Hand off the production-ready deliverables — workflows, configurations, integration credentials in the password vault, vendor escalation contacts. The business owner is the named operational owner going forward, not the project manager.

End-user training for advisors and CSAs on the new tooling, plus a runbook for ops covering common errors, vendor escalation paths, and the BAU support model. Record the training session — new hires next quarter need it too.

Define a 30-day hypercare window with a named escalation owner, a daily standup for the first week, and a defect triage cadence. Communicate the end date so the business knows when normal SLAs resume.