Portfolio Management Checklist

Retrieve the signed Investment Policy Statement, the most recent risk-tolerance result (Nitrogen / Tolerisk), and any account-level constraints — concentrated stock restrictions, ESG screens, withholding instructions for retirement accounts. Stale IPS documents are a frequent SEC exam finding.

Re-run the client's risk number if it has been more than twelve months or if the client has flagged a life event. Compare the current portfolio's risk score to the client's number — gaps over five points usually signal a needed conversation, not just a trade.

Revise the IPS to reflect the new objectives, risk number, time horizon, or liquidity needs. Route to the client for signature before any trading occurs against the new policy. Do not backdate the effective date.

Pull the firm's quarterly CMA update from the Investment Committee and confirm the model allocations still reflect committee-approved expected returns, vols, and correlations. Note any committee-driven model changes since last quarter.

Use iRebal, Eclipse, or Tamarac to compute drift at the asset-class and sleeve level. Flag any sleeve outside the firm's tolerance band (commonly +/- 5% absolute or +/- 20% relative). Note the trigger: threshold-based, calendar-based, or both.

Scan taxable accounts for unrealized losses and pair with replacement positions that avoid the 30-day wash-sale window across all related accounts (including the client's spouse and IRAs). Holistiplan or the custodian's tax-lot report is the right starting point.

Build the rebalance trades as a single block where possible to ensure fair allocation across accounts. Specify lot selection (HIFO / FIFO / specific lot) per account and confirm settlement timing for any anticipated distributions.

Capture the why — alternatives considered, costs, tax impact, alignment with the IPS — for each recommendation. Reg BI and DOL PTE 2020-02 exam staff want the rationale documented contemporaneously, not reconstructed at audit time.

Route the staged trades to the supervising principal or CIO for sign-off before release. Trades that hit the custodian without principal review create an FINRA Rule 3110 supervision gap on the BD side and a fiduciary documentation gap on the RIA side.

Confirm Black Diamond, Orion, or Tamarac positions tie to the Schwab / Fidelity / Pershing custodial statement to the share. Reconciliation breaks left unaddressed flow into performance numbers and fee billing — both client-impacting and exam-visible.

Run TWR for benchmark comparison and IRR / MWR for the client's actual experience including contribution and withdrawal timing. GIPS-aligned firms should also confirm composite assignment if the account is in a composite.

Use the IPS-defined blended benchmark, not a generic 60/40. Document attribution at the asset-class level — what drove over- or under-performance — so the quarterly review conversation can be specific rather than hand-wavy.

Identify any single security exceeding the firm's concentration cap (commonly 5-10% of account value), any sector overweight outside model bands, and any legacy low-basis position the client has flagged as a hold.

Run a 2008-style equity drawdown, a rates-up shock, and a credit-spread widening scenario against the current allocation. Note expected drawdown vs. the client's stated maximum tolerable loss from the IPS — this is the gap to surface in the review.

Cross-check holdings against the firm's restricted list, watch list, and any client-specific exclusions (employer stock for insiders, ESG screens, religious screens). Pre-clearance violations are a Code of Ethics finding under Rule 204A-1.

Apply firm policy thresholds to every taxable account. Document any approved exceptions (concentrated employer stock, low-basis legacy positions) with the client's signed acknowledgment of the concentration risk.

For any account with a standing letter of authorization to a third party, confirm the seven IM Guidance conditions are met — written client authorization, transfer to a specific account, custodian sends notice, etc. Missing safeguards trigger inadvertent custody and the surprise-exam requirement.

Confirm advisor and staff personal-trading reports for the quarter are filed in ComplySci or MyComplianceOffice and reviewed. Any gift over the firm's de minimis (commonly $100) or any entertainment requires log entry and CCO sign-off.

Deliver via NetDocuments / ShareFile / Black Diamond client portal — never personal email. Include the performance report, fee disclosure, and any updated Form ADV summary if there were material changes during the quarter.

Cover performance vs. the IPS benchmark, attribution, drift and rebalance actions, and any changes to the financial plan since last meeting. Keep the conversation tied to the client's goals from the plan, not just the market narrative.

Record discussion points, client-stated goals or concerns, and any follow-up tasks in Wealthbox or Redtail within one business day. Off-channel notes (text, personal email, paper) create the same SEC books-and-records gap that drove the 2022-2024 enforcement wave.