The year-end records checklist for small RIAs
A year-end records check is a short review a small RIA does before the year closes to confirm its core records are current and complete. Check eight: the discretionary account list, suitability reviews, IPS review dates, Q4 billing inputs, the complaints and incidents log, written procedures, brochure delivery records, and a dated full export saved somewhere the firm controls.
January at a small RIA is crowded. The Q4 bill in arrears runs, annual client reviews start, and the planning for next year all lands in the same few weeks. Gaps in the records found in January get fixed in a hurry, or not at all. The same gaps found in the first week of December can be fixed quietly, with time to spare.
What should a small RIA check at year end?
Eight records, each with one thing to confirm.
| # | Record | What to confirm |
|---|---|---|
| 1 | Discretionary account list | Every account's status is current; nothing changed without the list changing. |
| 2 | Suitability reviews | Who was reviewed this year, who is overdue, who is due in Q1. |
| 3 | IPS review dates | Which documents reach their review date in the next 90 days. |
| 4 | Q4 billing | Balances, exclusions and rates ready; last quarter reconciled to what the custodian deducted. |
| 5 | Complaints and incidents log | Reviewed and dated, even if it is empty. |
| 6 | Written procedures | Each has an owner and a review date, and still matches how you work. |
| 7 | Brochure deliveries | Proof of delivery filed, not left in an inbox. |
| 8 | Full export | A dated export of your records saved somewhere you control. |
When should you do the year-end check?
Early December. That leaves enough time to chase a missing signature or re-run a reconciliation before the holidays, and before the Q4 billing run in January depends on the inputs being right.
Why review an empty complaints log?
Because a dated review shows the log is kept on purpose. An empty log with no review date looks the same as a log nobody opens. A one-line entry such as "Reviewed 4 December, no complaints or incidents this year" takes a minute and answers the question before anyone asks it.
What does the check look like at a small firm?
Take a hypothetical three-person RIA with about 150 households, doing the check in the first week of December.
- Discretionary list. Two accounts moved to non-discretionary during the year when clients wanted to approve trades. One was updated on the list; the other wasn't. Fixed, with the date of the client's request.
- Suitability. 131 households reviewed this year, 7 overdue, 22 due in Q1. The 7 overdue get calls before Christmas.
- IPS. 14 documents reach their review date by March. Those meetings get booked now, alongside the Q1 suitability reviews where the households overlap.
- Billing. Q3's bill reconciled to the custodian's deductions except for one account where a mid-quarter withdrawal wasn't prorated. Corrected before Q4 runs.
- Brochures. 3 new clients' brochure deliveries were sent by email but never filed. Saved to the client records with the original send dates.
- Export. A full export saved to the firm's own storage, named with the date.
None of these are dramatic. Each would have been harder to sort out in February, when the people involved remember less.
How long does a year-end check take?
For a small firm with records in one place, about an afternoon. If the records are spread across a CRM, spreadsheets and shared folders, the first year takes longer. Keep a note of which check took longest. That's next year's improvement plan.
| Where records live | What slows the check down |
|---|---|
| One system | Fixing what you find, not finding it |
| CRM plus spreadsheets | Matching account lists across the two |
| CRM, spreadsheets and email | Finding proof of brochure delivery and signed documents |
What should you carry into January?
- The list of suitability and IPS reviews due in Q1, already scheduled.
- Any procedure that needs updating, with an owner and a date.
- Q4 billing inputs confirmed, ready for the arrears run.
When is a formal year-end check overkill?
If your firm already runs these checks quarterly, year end is just the fourth quarter's check with an export added. There's no need to make it a separate project. And a solo advisor with a dozen households may get through all eight in under an hour. The export and the dated complaints-log review are worth doing at any size.
How Advorra helps
In Advorra, the discretionary register, suitability-review clock, IPS review clock, billing blotter, complaints log, procedures vault and brochure-delivery log sit in one place, and a records production pack bundles the categories an examiner typically asks for. If you'd like your December check to start from one screen, see the product page, or read what audit-ready means.
General information, not legal or compliance advice.
Questions advisors ask
Who should do the year-end check at a two-person firm?
Ideally the person who didn't keep the record. A second pair of eyes catches what the owner reads past, and it means two people know where everything is.
What if I find a gap I can't fix before year end?
Write down what's missing, why, and when it will be fixed, and date the note. Don't backdate a record to make it look complete.
Should the year-end export include closed accounts and former clients?
Yes. A snapshot of what was on file at year end should include records you're still keeping for former clients, not only current ones.
How long should I keep each year's export?
As long as your retention policy says for the records in it. Your procedures and compliance consultant set that period.
Is this compliance advice?
No. It is a practical checklist. Your procedures, your regulator's rules and your compliance consultant govern your firm.
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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