Personal securities reporting for small RIAs: holdings and transaction reports, step by step
Personal securities reporting is the code of ethics process in which access persons report their own holdings and trades to the firm so personal trading can be checked against client trading. Under the SEC's Rule 204A-1, access persons generally file an initial holdings report within 10 days of becoming an access person, an annual holdings report at least once every 12 months, and quarterly transaction reports within 30 days after each calendar quarter ends, with holdings information current to within 45 days. State-registered advisers follow their state's rules, which often have similar expectations.
In a two-person RIA, the access persons are usually the two people who run the firm. That makes personal trading reports feel like paperwork about yourself, filed with yourself. The reports still matter. They show that personal trading doesn't conflict with client trading, and they are part of the firm's records. The aim is a routine that takes minutes each quarter instead of a scramble once a year.
What does Rule 204A-1 require?
For SEC-registered advisers, Rule 204A-1 requires three kinds of report, each with its own deadline (17 CFR 275.204A-1):
| Report | Timing under Rule 204A-1 |
|---|---|
| Initial holdings report | No later than 10 days after becoming an access person; information current to within 45 days before that date |
| Annual holdings report | At least once each 12-month period, on a date you choose; information current to within 45 days before submission |
| Quarterly transaction report | No later than 30 days after the end of each calendar quarter |
State-registered advisers are governed by their state's rules. Many follow a similar pattern; check yours.
What doesn't need a separate report?
The rule lets a code of ethics skip some reports. The main ones, from the rule text:
| Exception | What it means in practice |
|---|---|
| Accounts the person has no direct or indirect influence or control over | Don't assume an account managed by someone else qualifies; document why it does, and check with your compliance consultant |
| Transactions under an automatic investment plan | Recurring purchases on a set schedule don't go on the transaction report |
| Reports that would duplicate confirms or statements | If the firm receives the broker confirms or statements within 30 days after quarter end, they can stand in for the transaction report |
| Securities outside the reportable definition | Including direct US government obligations and money market fund shares, among others listed in the rule |
The duplicate-statement exception is the one that saves most small firms time. It only works if the statements actually arrive and get filed within the 30 days. The rule also has a provision for a firm with only one access person, which changes who reports to whom but still requires the firm to keep records of the holdings and transactions. Read it in the rule text before relying on it.
A worked example
Take a two-person RIA with about 120 households and a calendar quarter routine. The firm is hypothetical. Both owners are access persons. Each has one personal brokerage account, and one also has an IRA.
- Setup, once: both brokerage firms are set to send duplicate statements to a shared compliance inbox. The firm chooses 31 January as its annual holdings date.
- Each quarter, by day 30: the duplicate statements for the quarter are saved to the compliance records and logged with the date received.
- Review: each owner reviews the other's statements against client trading in the same period. That takes about fifteen minutes when the log is current.
- Annually: each owner submits a holdings report current to within 45 days, using the latest statements, and the other reviews it.
- When the firm hires: the new person's initial holdings report goes on the onboarding checklist with a 10-day deadline.
Cross-review solves the awkward part of a small firm: nobody reviews their own report. In a solo firm that option doesn't exist, which is why the single access person provision is worth reading closely.
What should the log show?
The log should show, for each report, who it's from, what period it covers, when it was received, who reviewed it and when, and any follow-up. If the report is a duplicate statement, note which account it covers. A log like this answers the questions someone will ask first without anyone digging through email.
Where does this usually go wrong?
- A new hire's initial holdings report is never collected.
- Quarterly reports are collected but not reviewed, or reviewed with no record of it.
- Duplicate statements stop arriving after a broker change and nobody notices for two quarters.
- Reports are stored in email with no log showing what came in and when.
When is a full routine overkill?
A firm whose access persons hold only mutual funds and money market funds that fall outside the reportable definition has very little to report. It still needs the annual and initial holdings reports where the rule requires them, and a record of why there is nothing on the quarterly reports. The quarterly routine shrinks to a short confirmation. Don't skip the record of that confirmation; an empty log looks the same as a forgotten one.
How Advorra keeps it
Advorra keeps a personal-securities log among the firm's compliance records, alongside the procedures and other registers, and includes it in the records production pack. If your quarter-end reports are due soon, see how the log works on the product page, or read RIA books and records.
General information, not legal or compliance advice. Rule quotations from 17 CFR 275.204A-1 as published by the Legal Information Institute, October 2026. Your code of ethics, your state's rules and your compliance consultant govern your firm.
Questions advisors ask
Who is an access person?
Generally, a supervised person with access to nonpublic information about client trading or holdings, or who makes or is involved in recommendations. In a small RIA that is often everyone. Your code of ethics defines it for your firm.
Do I need to report money market funds and Treasuries?
Rule 204A-1 excludes some securities from the definition of a reportable security, including direct US government obligations and money market fund shares, among others. Check the full list in the rule and your code of ethics.
Do I need approval before buying into an IPO?
Under Rule 204A-1, the code must require access persons to get the firm's approval before acquiring securities in an initial public offering or a limited offering. In a one-person firm, the single access person exception changes how this works; see the rule.
What if a spouse has a brokerage account?
Reporting generally follows beneficial ownership, which can include accounts of household members. Your code of ethics should say how your firm treats them. Ask your compliance consultant if it's unclear.
Is this compliance advice?
No. It summarises a rule and a routine. State-registered advisers should follow their state's rules and their compliance consultant.
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.
Get in touch