Client Communication Checklist

CSA records the client's primary email, mobile, and preferred channel (call, secure portal, email, text) in the CRM (Wealthbox / Redtail / Salesforce FSC). If the client wants text, route through MyRepChat or Hearsay Relate — personal SMS is off-channel and archives nothing.

Reg BI requires Form CRS at the first recommendation or new account; Reg S-P requires the privacy notice at the start of the relationship. Send through the document portal (NetDocuments / DocuSign / ShareFile) so delivery and timestamp are retained per 204-2 books and records.

The CSA sends the welcome packet with portal login (Black Diamond / Orion / Addepar), advisor and CSA contact, and the firm's service cadence. Confirm the client has logged into the portal at least once before the first review meeting.

Lead advisor books the discovery meeting within the first week. Send the data-gathering questionnaire (eMoney / RightCapital / MoneyGuide intake) and the document request list 48 hours ahead so the meeting isn't spent reading statements.

Segment the household (A / B / C or platinum / gold / silver) and set the recurring cadence in the CRM: annual review, semiannual planning touch, quarterly performance call, monthly check-in for HNW. Flag RMD clients, concentrated-position clients, and complex-tax clients for additional outreach.

Generate the quarterly statement in Black Diamond / Orion / Tamarac and reconcile against the custodian (Schwab, Fidelity, Altruist, Pershing) before sending. Performance presentations must conform to firm advertising policy under SEC Rule 206(4)-1 — net-of-fee returns, benchmark, and required disclosures.

Walk the client through performance, drift vs. target allocation, and any planning changes (job change, inheritance, health event, RMD year approaching). Log meeting notes in the CRM the same day — books-and-records rule 204-2 requires retention of advisory communications.

Re-run the Riskalyze / Nitrogen / Tolerisk profile if the client signals a change. Document the new risk number and the recommendation rationale — Reg BI exams want to see the why behind any allocation shift, not just the new model.

Revise the Investment Policy Statement to reflect the new risk profile and target allocation. Capture the recommendation rationale (why this model vs. alternatives, tax implications, expected drift) per Reg BI and DOL PTE 2020-02 documentation standards. CCO signs off before trades are placed.

All retail communications go through principal pre-approval under FINRA Rule 2210 (BD side) or the firm's advertising review process under SEC Rule 206(4)-1 (RIA side). Log the approver, date, and version in ComplySci or MyComplianceOffice before distribution.

CCO or designee spot-checks Smarsh / Global Relay / Microsoft Purview for the period. Off-channel comms (personal email, personal text, WhatsApp) are the #1 SEC enforcement action 2022–2024 — over $2B in fines across BDs. Any gap goes to the remediation log.

Any written grievance (email, letter, portal message) goes on the firm complaint log the same day it's received. FINRA Rule 4530 and most state RIA rules require a written complaint log with date received, complainant, nature of complaint, and resolution. Acknowledge receipt to the client within 24 hours.

Suitability, unauthorized trading, churning, misrepresentation, or theft allegations go to the CCO immediately. These can trigger Form U4 disclosure within 30 days and may require state or FINRA notification. Do not allow the named representative to investigate their own complaint.

CCO determines whether the complaint meets Form U4 Question 14I reporting thresholds (written, investment-related, alleges sales practice violation, damages $5K+). If yes, amend U4 in CRD within 30 days of the firm becoming aware. Document the analysis whether or not disclosure is required — examiners ask either way.

Export emails, texts, and call recordings from Smarsh / Global Relay for the relevant window. Pull trade tickets and any LOAs from the custodian. Compare against the IPS, signed advisory agreement, and risk profile in effect at the time.

Lead advisor drafts; CCO reviews before sending. State the findings, the proposed remedy (restitution from the error account, fee credit, account correction, or denial with rationale), and the client's escalation path. Avoid admissions of fault without CCO sign-off.

Process the fee credit, restitution journal, or account correction through the custodian. Trade errors clear through the firm error account within the firm's standard 5-business-day SLA. Reconcile the client's statement after the next cycle to confirm the remedy posted correctly.

If the client rejects the proposed resolution, CCO reviews the file and either authorizes a revised remedy or prepares the firm's position for potential FINRA arbitration / state regulator inquiry. Notify the firm's E&O carrier of any matter likely to become a claim.