Code of ethics acknowledgments: collecting them every year without the chase
A small RIA can collect code of ethics acknowledgments without chasing by tying them to fixed moments: when someone joins, when the code changes, and once a year on a set date. Record who signed, which version, and the date, and keep the signed copies with the code itself. Your compliance consultant can confirm exactly what your registration requires.
Every December the operations lead at a small firm sends the same email: "Can everyone sign the code of ethics acknowledgment?" Two people reply in an hour. One replies in January. Nobody is quite sure which version last year's signatures were for. The work itself takes five minutes a person. It's the chasing and the missing paper trail that cost the time.
When should acknowledgments happen?
| Moment | Why |
|---|---|
| When someone joins | Before they start working with clients or client information |
| When the code changes | Everyone should have read the version in force |
| Once a year, on a fixed date | A predictable moment, not a December scramble |
What should the record show?
- The person's name and role.
- The version of the code (and any other policy) they acknowledged.
- The date they signed.
- Where the signed copy is kept.
The routine
- Pick the annual date and put it on the compliance calendar. Many firms tie it to the annual review.
- Send the current version with a short note: what changed, if anything, and the date you need it back.
- Record each signature as it arrives: name, version, date.
- Follow up once on the deadline. Note any gap and the date it closed.
- File the signed copies with the code itself, not in an inbox.
A worked example
Take a hypothetical three-person RIA. It moves its acknowledgment date from "sometime in December" to 15 March, right after its annual review. The operations lead sends the current code with one line on what changed. Two signatures come back the same day and one the next week; each is recorded with the version and date. When a new associate joins in June, they sign on day one. Next year, nobody has to remember who signed what.
What are the common gaps?
- No record of which version someone signed.
- New joiners who never signed because the annual round hadn't come yet.
- Signed copies scattered across email.
- Code changes rolled out with no fresh acknowledgment.
When is this overkill?
For a solo advisor, it may come down to signing your own code each year and noting the date. Check with your compliance consultant what applies to you.
How Advorra fits
Advorra keeps compliance records in one place: a procedures vault for your policies and their versions, a personal-securities log, a complaints and incidents log and a brochure-delivery log, with a records-production pack when someone asks for them. See the product page, or read about personal securities reporting and the compliance calendar.
One thing to do this week: put a fixed date for code of ethics acknowledgments on next year's calendar.
An operations routine, not legal or compliance advice. Your code of ethics and your compliance consultant set the requirements.
Questions advisors ask
Who needs to sign?
Usually everyone covered by the code, which at a small firm is often everyone. Your code and your compliance consultant decide the exact list.
When should people sign?
When they join, whenever the code changes, and once a year on a fixed date.
What should we record?
The person, the version of the code they acknowledged, and the date.
What if someone hasn't signed by the deadline?
Follow up once, then note the gap and the date it was closed. A dated note beats a silent gap.
Is this compliance advice?
No. It is an operations routine. Your code and your consultant set the rules.
See it on a demo firm
Advorra is practice software for independent RIAs: clients, models, IPS, billing and compliance records in one place, on top of the custodian you already use. Built by The CollabHub.
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