Examination Readiness Checklist
Documents and evidence, organized by functional area, that should be organized, current, and readily accessible at all times — not assembled only when an examination is announced.
Registration and organizational:
- Current Form ADV Parts 1, 2A, 2B (and all amendments filed during the review period)
- Current Form CRS (for dual registrants)
- Form BD and FINRA membership documents (for broker-dealers)
- Organizational charts reflecting current structure
- Ownership and control documentation
- List of affiliated entities and related persons
- State registration filings
Compliance program:
- Written compliance policies and procedures (current version with revision history)
- Code of ethics (current version)
- CCO designation documentation
- Annual compliance review report (current and prior two years)
- Compliance committee or management meeting minutes
- Compliance calendar showing scheduled activities and deadlines
- Compliance testing reports and results
- Regulatory correspondence file (all communications with SEC, FINRA, state regulators)
- Prior examination deficiency letters and the firm's responses
- Remediation tracking documentation
Trading and investments:
- Trade blotters and order tickets
- Trade allocation records and allocation policies
- Best execution review documentation
- Soft dollar arrangement records and Section 28(e) analysis
- Brokerage committee or trading committee minutes
- Directed brokerage documentation
- Error correction log and resolution documentation
Advertising and marketing:
- Advertising review log (all materials reviewed, with dates, reviewer, and disposition)
- Copies of all advertisements disseminated (print, digital, social media, email)
- Social media archives (all platforms used by the firm and associated persons)
- Performance calculation support (worksheets, data sources, methodologies)
- Hypothetical performance policies and procedures
Custody and client assets:
- Custody determination analysis
- Surprise examination engagement letter and report (if applicable)
- Qualified custodian statements (confirming direct client delivery)
- Fee deduction authorization documentation
AML and financial crimes:
- AML compliance program (written procedures)
- AMLCO designation
- AML independent testing report (current and prior year)
- AML training records
- SAR filing records and supporting documentation
- OFAC screening records and procedures
- Customer risk rating documentation
Cybersecurity:
- Written information security policy
- Incident response plan (current, tested) — including the Reg S-P incident response program required since the 2024 amendments
- Business continuity plan (current, tested)
- Vulnerability assessment and penetration testing reports
- Vendor due diligence files for technology service providers
- Data breach notification records (if any)
- Employee cybersecurity training records
Books and records:
- Financial statements (current and prior two years)
- FOCUS reports (broker-dealers)
- Net capital computations (broker-dealers)
- Customer reserve computations (broker-dealers)
- Client agreements (advisory and brokerage)
- Fee schedules and billing records
- Complaint log and complaint files
- Personal trading reports (initial and annual holdings, quarterly transactions)
- Gifts and entertainment log
- Outside business activity records
- Political contribution records