Client Onboarding Checklist

The lead advisor walks the prospect through scope of services, account types in play (taxable, IRA rollover, trust, 529), and rough AUM expectations. Capture the client's stated goals, time horizon, and any complexity flags — concentrated stock, business interests, inherited assets, NQDC.

State whether the engagement is AUM, flat, hourly, or blended, and confirm the prospect understands billing frequency and how the first prorated fee will be calculated. Mismatched fee expectations surface as complaints later.

Reg BI requires Form CRS delivery to retail clients at the time of recommendation or before a new account opens — not at file close. Send via the document portal so delivery is timestamped and retained.

Route the IAA through DocuSign or RightSignature. Confirm the fee schedule, services, and termination terms match what was discussed in discovery — boilerplate from a prior engagement is a common source of mismatch.

Send the firm brochure (2A), the brochure supplement for the assigned advisor (2B), and the Reg S-P privacy notice. Use the portal so the delivery date is captured for the annual ADV offering audit.

Pull executed acknowledgments for the IAA, Form CRS, ADV 2A/2B, and privacy notice into the client's compliance folder in NetDocuments or Box. CCO will check for these in the file-close review.

Have the client complete the risk questionnaire independently rather than walking them through the answers. The resulting risk number anchors the Reg BI / fiduciary recommendation rationale captured later.

Driver's license or passport plus a second proof of address. Run identity verification through LexisNexis Bridger or IDology and retain the result. Manual review for any non-pass.

For trusts, LLCs, and partnerships: collect the trust certification or operating agreement, EIN letter, and identity verification for every 25%+ beneficial owner plus one control person. Skipping beneficial-owner collection on entities is a top AML exam citation.

Screen the client, joint owner, beneficial owners, trustees, and named beneficiaries against the SDN list and PEP databases via World-Check or Bridger. Document the screen result with date and reviewer — not just a pass/fail flag.

For PEP hits or high-risk geographies, capture source-of-wealth narrative, expected activity profile, and CCO sign-off before the account funds. EDD memo lives in the compliance folder.

Submit the new account paperwork through Schwab Advisor Center, Fidelity Wealthscape, Altruist, or Pershing NetX360. Confirm registration type (individual, JTWROS, trust, IRA), tax ID, and fee billing authorization on each account.

Verify the linked bank by micro-deposit or aggregator login. Any future change to wire instructions requires verbal call-back to a known number — wire-fraud loss from email-only changes has been the single largest operational hit at peer firms.

Pull the most recent statement from the delivering firm and submit ACATS through the custodian portal. Flag partial vs. full and in-kind vs. cash on the request. Non-ACATS-eligible positions (alts, proprietary funds) need a separate transfer path.

Compare CUSIP-level positions and cost basis on the receiving statement to the delivering statement. Missing basis on transferred lots is common and must be requested from the prior custodian within 90 days, otherwise the client receives Form 8949 with non-covered gaps.

Stage trades in iRebal, Tamarac, or Orion Eclipse. Watch for short-term gains on transferred lots and wash-sale risk if the client holds the same position personally elsewhere. Tax-aware implementation often means staging into the model over weeks, not all on day one.

Capture why this model fits the client's risk profile, time horizon, and tax situation — and why alternatives were not selected. Reg BI exams want the "why," not just a checked box. The risk number from Nitrogen and the planning output from eMoney or RightCapital both support the rationale.

Client service associate sends the welcome email with portal credentials, advisor team bios, and the planned service cadence (quarterly review, annual planning meeting). Confirm the client has logged into the custodian portal and the firm's reporting portal at least once.

CCO reviews the file for completeness: signed IAA, CRS/ADV/privacy acknowledgments, KYC and CDD records, OFAC screen, EDD memo if applicable, risk profile, and Reg BI rationale. File close is the last gate before the account is considered fully onboarded.