Electronic delivery consent: what a small RIA should record
A small RIA that sends documents by email or a portal should record, for each client, whether they agreed to electronic delivery, the date, which documents it covers and the email address it applies to. Then keep evidence that each required document was actually delivered: what was sent, to whom, when and how. Clients who prefer paper get paper, and that preference is recorded too. Your compliance consultant can confirm what your procedures need.
At a records review, someone asks how the firm delivered last year's brochure update to a particular client. The answer is "we email everything." Then the next question: did that client agree to email delivery, and is there a record it went to the right address? A routine habit turns into a search through old inboxes.
What should you record for each client?
| Item | Example |
|---|---|
| Consent to electronic delivery | Yes, signed at onboarding |
| Date | When they agreed |
| Documents covered | Brochure, privacy notice, agreements, reports |
| Email address it applies to | The address on file, verified |
| Paper preference, if any | Which documents, and since when |
And for each delivery
- What was sent, and which version.
- To whom, and to which address.
- The date and the method: email, secure link, portal or post.
- Any bounce or returned mail, and what you did about it.
The routine
- Ask for electronic delivery consent at onboarding, as part of the paperwork.
- Record it on the client's record with the date and documents covered.
- When an email address changes, confirm it through details already on file before using it.
- Log each required delivery as it goes out.
- Check bounces the same week and resend by another method.
A worked example
Take a hypothetical two-person RIA sending its annual brochure offer to 70 households. Sixty-four have electronic consent on file and get a secure link; each delivery is logged with the date. Two emails bounce, so those clients are called, their addresses corrected, and the brochure resent. Six prefer paper and get it by post, logged the same way. When the next records request comes, the answer for any client is one look at their record.
What are the common gaps?
- "We email everything" with no consent on file.
- Deliveries with no date or version.
- Bounced emails nobody followed up.
- Paper-preference clients switched to email by mistake.
When is this overkill?
It isn't, for required documents. For everyday notes and meeting follow-ups, ordinary email records are usually enough.
How Advorra fits
Advorra keeps a brochure-delivery log and communications on each client's record, alongside its compliance registers and a records-production pack, so what was sent, to whom and when is easy to find. See the product page, or read about brochure delivery records and sharing client documents securely.
One thing to do this week: check whether your onboarding paperwork asks for electronic delivery consent.
An operations routine, not legal or compliance advice. Your compliance consultant can confirm what your procedures need for electronic delivery.
Questions advisors ask
Do we need consent to email clients documents?
Regulators' guidance on electronic delivery generally looks for notice, access and evidence of delivery, and many firms get consent at onboarding. Your compliance consultant can confirm what your firm needs.
Where should consent be recorded?
On the client's record, with the date, the documents covered and the email address.
What counts as evidence of delivery?
A record of what was sent, to whom, when and by what method. A note saying "sent the brochure" without a date is weak.
What if a client wants paper?
Send paper, and record that preference so nobody switches them back by accident.
Is this compliance advice?
No. It is an operations routine.
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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