Client Onboarding Checklist

Capture scope of services, account types in scope (taxable, IRA, trust, 401(k) rollover), AUM expectations, and any complexity flags (concentrated stock, NUA, RMD client, non-spousal inherited IRA). Log the call notes to the CRM (Wealthbox / Redtail / Salesforce FSC) the same day so the engagement record matches what gets disclosed downstream.

Reg BI Form CRS must be delivered no later than the first recommendation, opening a new account, or beginning a new service. Email through the document portal with read receipt, or capture a wet/electronic acknowledgment — Form CRS delivery gaps are a recurring SEC exam finding.

Send the IAA via DocuSign or RightSignature. Verify the version matches the latest reviewed by the CCO, that fee schedule and discretionary authority language are consistent with ADV Part 2A, and that all account owners have signed (both spouses on a JTWROS, all trustees on a trust account).

Send the firm brochure (2A) and the brochure supplement (2B) for the servicing advisor at or before engagement. Capture acknowledgment of receipt in the CRM — the annual ADV cycle workflow keys off this initial delivery date.

Collect government-issued photo ID and verify the four CIP data points: legal name, DOB, address, and TIN/SSN. Run through LexisNexis Bridger or the custodian's CIP verification; retain the cleared report in the client folder.

Individual, JTWROS, revocable trust, IRA (traditional, Roth, inherited), or entity (LLC, S-corp, partnership, foundation). Entity and trust accounts trigger beneficial owner collection under the CDD rule; inherited IRAs trigger the 10-year SECURE Act payout rules.

Per the CDD rule, collect identity information for every individual owning 25% or more of the entity plus one control person (CEO, managing member, general partner). Also confirm CTA beneficial ownership reporting status with the entity's counsel — that's the entity's filing, not ours, but it affects the file.

Screen every account owner, trustee, beneficial owner, and named beneficiary against the OFAC SDN list and PEP sources. Re-screen on any party change later in the relationship; a beneficiary added six months in who appears on SDN creates the same violation as a Day-1 miss.

Submit the new account paperwork through Schwab Advisor Center, Fidelity Wealthscape, Altruist, or Pershing NetX360. Confirm the account is established NIGO-free and that the client has registered on the custodian portal — unactivated portal access is a downstream service complaint waiting to happen.

Establish the funding link with two-penny verification or aggregator-based instant linkage. Any later change to the linked bank or wire instructions must be confirmed verbally on a call-back to a known number — written-only changes are the dominant wire-fraud vector against advisory clients.

Submit ACATS using the most recent delivering-firm statement. Decide full vs. partial, in-kind vs. liquidate, and flag any non-ACATS-eligible positions (alts, non-traded REITs, proprietary funds) for separate TOA paperwork. Communicate the 5–10 business day expectation to the client up front.

Write the why: how the target allocation matches the captured risk profile, why this model vs. reasonably available alternatives, and how cost was weighed. For rollover recommendations from a 401(k) or pension, the PTE 2020-02 best-interest determination goes here in writing.

Apply the target model through iRebal, Tamarac, or Eclipse. For taxable accounts, screen for short-term gains, wash sales against personal accounts, and tax-lot selection — the most expensive onboarding error is liquidating a low-basis position the client expected to hold.

Package IAA, signed CRS and ADV acknowledgments, CIP and CDD documentation, OFAC screen, risk profile, recommendation rationale, and account agreements into NetDocuments or Laserfiche under the client folder structure. This is the file an SEC exam will request first.