Advorra blog

Brochure delivery records for RIAs: what to record and when

By the team at The CollabHub · Co-written with Mohammad Aamish Aaftab
Published 4 Oct 2026 · Updated 17 Oct 2026

A brochure delivery record is a dated entry showing which version of the brochure or supplement went to which client, how, and when. For SEC-registered advisers, Rule 204-3 generally requires delivering the brochure before or at the time of entering into an advisory contract, delivering the current brochure or a summary of material changes within 120 days after fiscal year end when there have been material changes, and delivering a supplement before a supervised person starts advising the client. State-registered advisers follow their state's rules, which are often similar.

A new client signs on a Tuesday. The brochure went out with the welcome email on Monday, so the delivery happened. Eighteen months later someone asks you to show it. The proof is an attachment in a sent folder, from an address that has since changed, with no note of which version it was. That's the gap this post is about.

What is a brochure delivery record?

A brochure delivery record is a dated entry showing which document went to which client, by what method. It turns a delivery you know happened into one you can show happened. The delivery itself is rarely the problem. Most advisers attach the brochure to onboarding emails without thinking about it. The record is what gets skipped.

When does Rule 204-3 require delivery?

For SEC-registered advisers, Rule 204-3 sets the timing for the brochure (Form ADV Part 2A) and supplements (Part 2B) (17 CFR 275.204-3):

The fourth row is the one firms forget, because it doesn't follow the annual calendar. State-registered advisers are governed by their own state's rules, which often follow a similar pattern. Check your state's rule text rather than assuming.

What should each delivery record show?

Each record should show five things, enough that someone who wasn't there can confirm the delivery without asking you.

A worked example

Take a two-person RIA with about 120 households and a calendar fiscal year. This firm is hypothetical. It amends its brochure in March with a material change to its fee schedule.

1. By the end of April, 120 days after year end, it must deliver the update to every client. It builds a list of all 120 households from the client list, not from memory.
2. It sends the summary of material changes with an offer of the full brochure, and logs each household with the date and method as the emails go out.
3. Six households bounce or have no current email. Those six get paper copies, logged as paper with the posting date.
4. In June, a new adviser joins and starts meeting clients. Before each first meeting, the firm delivers her supplement and logs it per client.
5. In December, it compares the log to the client list. Two households onboarded in November have a brochure entry but no supplement for the adviser who met them. Those get fixed and logged with the real date.

Step 5 matters most. A check against the client list is what finds the missing entries, and finding them yourself in December is far better than someone else finding them later.

How do you build delivery into the routine?

• At onboarding, make brochure delivery a step that must be complete before the client is marked onboarded.
• After the annual amendment, list every client who should receive the update and tick each one off with a date.
• When a new person starts advising clients, record supplement delivery for each of their clients.
• Once a year, compare the log to your client list for anyone missed.

When is a full log overkill?

A solo adviser with fifteen clients who sends every document through a portal that keeps its own delivery history may not need a separate log for each send. The portal's record can be the proof, as long as you can export it and it shows the version. The log becomes necessary once deliveries go through more than one channel, or once you have more clients than you could list from memory. At that point a gap in one channel is invisible unless all of them land in one place.

How Advorra records it

Advorra keeps a brochure-delivery log among the firm's compliance records, and the prospect journey records when and how the brochure was sent, with the email attached, before the prospect becomes a client. The log is part of the records production pack. If your annual update is coming up, see how the log works on the product page, or read the client onboarding checklist.

General information, not legal or compliance advice. Rule quotations from 17 CFR 275.204-3 as published by the Legal Information Institute, October 2026. State-registered advisers should rely on their state's rules.