Regulatory Reporting Checklist

Identify the exact filing — Form ADV Annual Update, ADV Amendment, Form CRS, Form PF, 13F, FOCUS, SAR, CTR, HMDA LAR, or other — and the regulator (SEC, FINRA, state securities, FinCEN, CFPB). The right filing type drives the portal, the data scope, and the books-and-records retention period.

Confirm the statutory deadline (e.g., ADV annual update within 90 days of fiscal year end; SAR within 30 days of detection; 13F within 45 days of quarter end). Add the filing to ComplySci / RIA in a Box / internal calendar with reminders 30, 14, and 5 days out.

Export the period-end positions, AUM, and transaction data from Schwab / Fidelity / Pershing / Altruist and from the portfolio system (Black Diamond, Orion, Tamarac, Addepar). Pull as of the regulatory as-of date — not today.

Tie internal AUM and share counts to custodian statements at the account level. Common reconciling items: pending corporate actions, in-flight ACATS, sweep balances, fractional shares.

Work each break to closure with the custodian and ops. Document the cause (timing, classification, missing trade, corporate action) and the corrected number. Do not proceed to calculations on unreconciled data.

Generate the report in the filing system — IARD draft for ADV, FINRA Gateway draft for FOCUS, FinCEN BSA E-Filing draft for SAR/CTR. Confirm the as-of date, reporting period, and CRD/IARD/RSSD identifiers match.

Compare each line item to the prior filing. Flag any variance over the firm's materiality threshold (commonly 5% or $1M, whichever is lower). Material variances require documented explanation before sign-off.

For each material variance, write a one-paragraph explanation citing the underlying driver (market move, AUM inflow/outflow, methodology change, restated prior period). Attach to the workpaper file. This is the first thing exam staff ask for.

CCO walks the draft against the prior filing, the variance memo, and any open regulatory matters. Reviewer comments go in the workpaper, not in chat.

Each comment gets a written response — accepted and revised, or rejected with reasoning. Re-run validations after edits; do not assume a small change won't ripple.

File via the correct portal — IARD for ADV, FINRA Gateway for FOCUS, EDGAR for 13F, FinCEN BSA E-Filing for SAR/CTR, HMDA Platform for HMDA. Do not file from a personal account; use the firm's filer credentials.

Save the timestamped confirmation, accession number, or BSA tracking ID. Without the receipt, you cannot prove timely filing if the regulator's system later loses the entry.

Move the final filing PDF, workpapers, variance memo, CCO review comments, principal signature, and confirmation receipt into the books-and-records archive. Lock the folder against further edits.