Practice Process Improvement Review

Send the NPS survey to all active households segmented by service tier (A/B/C). Pull the response rate and category averages from the CRM (Wealthbox, Redtail, Salesforce FSC). A response rate under 25% usually means the survey is being sent from a no-reply address or buried in a newsletter — fix the channel before drawing conclusions.

Pull the last quarter's not-in-good-order rate from the custodian dashboard (Schwab, Fidelity, Altruist, Pershing). Categorize by reason: missing signature, wrong account-type form, beneficiary missing, MDIA needed. NIGO above 15% usually means the CSA workflow is missing a pre-submission review step.

Pull the CRS delivery log from the CRM and reconcile against new-account openings and rollover recommendations for the period. Reg BI requires Form CRS at first recommendation and at any new account or service — gaps here are the most common SEC exam citation in retail RIA practices.

Walk the path from discovery call to first quarterly review with two recently-onboarded clients. Note handoffs (advisor → CSA → ops), wait times for ACATS, and any moment the client had to chase the firm for a status update.

Confirm A-tier households received their committed annual planning meeting and quarterly check-ins; B-tier received semiannual contact; C-tier received the standardized review. Missed-touch counts should be reported to the lead advisor for outreach.

Trace a partial and a full ACATS request from initiation through reconciliation. Common bottlenecks: delivering-firm rejections on title mismatches, in-kind positions that don't transfer, and reconciliation lag against the custodian feed.

Review every trade error and reconciliation break for the quarter. Confirm each error was funded out of the error account within the 5-day SLA and that root cause was logged. Repeat patterns (wrong allocation, wrong tax lot, wash-sale trip) point at rebalance-tool configuration in iRebal, Tamarac, or Orion Eclipse.

Three-way tie-out: fee invoice from Black Diamond / Orion / Tamarac, custodian fee debit, internal calculation. Verify the basis (period-end vs. average daily balance) matches the IAA. Billing errors are the fastest path to a client complaint and an ADV-level finding.

Targets the firm tracks: NIGO rate under 10%, ACATS median under 8 business days, error account balance closed within 5 days, fee reconciliation breaks at zero. Adjust thresholds based on last quarter's actuals, not aspirationally.

Run a 30-minute open session with the CSA and advisor pods. The people doing the work see the friction first — surface ideas before the ops manager prescribes a fix.

Confirm Part 2A and 2B were delivered within 120 days of fiscal year end to every existing client, plus any material-change interim updates. Track delivery by client and retain acknowledgment — this is the first thing an SEC examiner asks for.

Beneficiaries and authorized parties added mid-relationship are the typical gap. Re-screen all parties through World-Check or LexisNexis Bridger and document the clear result. SDN hits demand immediate freeze and escalation to the CCO.

Sample advisor texts and personal-email activity through Smarsh, Global Relay, or MyRepChat. Any client-facing communication on a non-archived channel is a recordkeeping violation — the SEC has fined firms across the industry over $2B for this since 2022.

For each rep with off-channel activity: document the scope, retrain on the comms policy, capture written attestation, and load to the supervised list for 90-day spot checks. Escalate repeat offenders to the CCO for written warning.

For every standing letter of authorization to a third party, confirm the seven SEC no-action conditions are met (signed third-party authorization on file, written confirmation to client, ADV custody disclosure, etc.). Missing any one tips the firm into custody and triggers the surprise exam requirement.

Walk the escalation path from front-line detection to BSA officer to FinCEN filing. Confirm the 30-day filing clock from suspicion is achievable with current staffing and that the narrative template covers the five W's.

List active licenses across CRM (Wealthbox, Redtail, Salesforce FSC), planning (eMoney, MoneyGuide, RightCapital), and reporting (Black Diamond, Orion, Tamarac, Addepar). Note seat utilization — paying for unused seats is a common waste.

Send test messages from each rep's archived channels and confirm capture in Smarsh / Global Relay. Validate LinkedIn and other social-media surfaces are routed through Hearsay or equivalent. Coverage gaps found here become the priority remediation for the quarter.

Engage the archiving vendor with the test-message evidence; require a fix or a documented workaround within 14 days. Document the gap window for the compliance file in case an exam asks.

Confirm MFA on the custodian advisor portals, CRM, planning software, document portal, and email. Review the admin-access list for terminated reps still showing entitlements — a finding here is also a Reg S-P / Identity Theft Red Flags exposure.

For each material vendor, refresh SOC 2 Type II report, BCP attestation, and breach-notification clause review. The CCO should sign off on the package as part of the third-party risk file.

Five-question anonymous pulse: workload, tooling, leadership clarity, growth path, intent to stay. Track the trend across quarters; a one-quarter dip is noise, two consecutive is a signal.

Confirm Series 65/66, CFP, CFA, and state insurance CE windows for every licensed team member. Flag anyone within 60 days of a deadline. A lapsed IAR registration is an immediate cease-advice issue.

Spell out the milestones: CFP completion, IAR registration, lead advisor on N households, revenue contribution. Without the path written down, paraplanners leave for firms that have one.

Block sessions for new-hire CIP/CDD training, Reg BI refresher, planning-software upgrades (Holistiplan, FP Alpha), and any custodian platform changes announced for the quarter.

The COO and CCO jointly approve the prioritized list of improvements with named owners and 30/60/90-day due dates. The signed plan goes into the firm's governance file and seeds the next quarter's review.