Books and records checklist generator

Pick the firm type and tick what the firm does, and get every record the rule text names for that firm: the ria books and records requirements of Rule 204-2, or a broker-dealer’s under Rules 17a-3 and 17a-4 and FINRA’s 4511 and 4512. Each row carries its paragraph and how long it is kept, and two columns you fill in yourself: who owns the record and where it lives.

Stipple engraving from above of an index tray of guide cards at staggered tab positions — A checklist is an index: every record filed under its rule, with a name against it.

What the checklist covers

The ria books and records requirements sit in one long paragraph list, Advisers Act Rule 204-2, and many of its items apply only when the firm does a particular thing: holds client assets, votes proxies, advertises performance. A broker-dealer’s list is split across two Exchange Act rules, 17a-3 for what to make and 17a-4 for how long to keep it, with FINRA Rule 4511 on top. The generator reads both lists for you and keeps only the rows that apply.

01Pick the firm type: an SEC-registered adviser, a broker-dealer, or both.
02Tick what the firm does. Each box adds only the records the rule ties to that activity.
03Read each row: the record, the paragraph that requires it, and how long it is kept.
04Fill in an owner and a place for every row, mark what is already in place, then Copy or Print.

The keep-for column is not typed twice. Each row points at a record class of the books and records retention calculator, so the period here is the one the calculator counts with. To turn a period into a keep-until date for a particular record, take it there. The owner and where-kept columns are yours to fill. For electronic records, Rule 204-2(g) asks an adviser to arrange and index them “in a way that permits easy location, access, and retrieval of any particular record”; a broker-dealer that keeps records electronically works to the 17a-4(f) storage conditions instead.

Worked example

The tool opens on one small-firm example: an SEC-registered adviser that manages client portfolios with discretion and advertises, but does not hold client assets, vote proxies or show performance. Start from the records every registered adviser keeps, then add what each activity brings.

A small discretionary adviser that advertises

Records added by each activity for the example adviser
What the firm does	Records	Paragraphs	Kept for
Every adviser, nothing ticked	24	7 groups: accounts and financial records, communications and agreements, brochures and form crs, code of ethics, compliance program, customer information (regulation s-p), firm documents	5 years under (e)(1); 5 years under (a)(12)(i), (a)(17)(i); 5 years under (a)(12)(iii), (a)(13)(ii); 3 years under (e)(2)
Discretion over client accounts	2	List of discretionary accounts (a)(8); Powers of attorney (a)(9)	5 years under (e)(1)
Manages or supervises client portfolios	1	Client purchase and sale records (c)(1)(i)	5 years under (e)(1)
Advertises	3	Each advertisement (a)(11)(i)(A); Communications to ten or more persons (a)(11)(i)(B); Reasons memorandum (a)(11)(i)(C)	5 years under (e)(3)(i)
The example, all three ticked	30

17 CFR 275.204-2(a), (c)(1)(i), (e)(1)-(e)(3)

The advertising rows are the ones with their own clock. Under 204-2(e)(3)(i) an advertisement’s five years run from the end of the fiscal year in which it was last disseminated, so a piece still in use keeps pushing its start date out; the Marketing Rule ad review checklist covers what has to be true of the ad itself. Tick custody and the list grows by 5 rows under 204-2(b) and (a)(17)(iii); tick proxy voting and it grows by 5 under 204-2(c)(2).

Three code-of-ethics rows look back rather than forward: the code itself, the acknowledgments and the list of access persons cover what was in effect, or who was in scope, “within the past five years”. The code of ethics guide walks through the reports behind those records.

The rule text

Every row of the checklist hangs from one of three sentences. Each one is a duty to make records, not only to keep them, and each ends in a list.

The adviser’s list adds two paragraphs that switch on with the business: 204-2(b), which applies if the adviser “has custody or possession of securities or funds of any client”, and 204-2(c), for an adviser that renders “any investment supervisory or management service” or “exercises voting authority with respect to client securities”. Those three phrases are the checkboxes in the tool. Before you rely on the list, have your compliance counsel read it against your business; it is a reading of the rule text, not legal advice.

Where the rule says so

Every row the tool can produce, by group, with the paragraph that requires the record and the one that sets its period. Open a group to read it. The full text is on the eCFR for Rule 204-2, Rule 17a-3 and Rule 17a-4.

Investment advisers: Rule 204-2

Accounts and financial records (6)

Journals and cash records. A journal or journals, including cash receipts and disbursements, and any other records of original entry.
17 CFR 275.204-2(a)(1); kept 5 years under 17 CFR 275.204-2(e)(1)
General and auxiliary ledgers. Ledgers reflecting asset, liability, reserve, capital, income and expense accounts.
17 CFR 275.204-2(a)(2); kept 5 years under 17 CFR 275.204-2(e)(1)
Order memoranda. A memorandum of each order given for the purchase or sale of a security, each instruction received, and any modification or cancellation; discretionary orders so designated.
17 CFR 275.204-2(a)(3); kept 5 years under 17 CFR 275.204-2(e)(1)
Check books and bank records. All check books, bank statements, cancelled checks and cash reconciliations.
17 CFR 275.204-2(a)(4); kept 5 years under 17 CFR 275.204-2(e)(1)
Bills and statements. All bills or statements, paid or unpaid, relating to the advisory business.
17 CFR 275.204-2(a)(5); kept 5 years under 17 CFR 275.204-2(e)(1)
Trial balances and financial statements. All trial balances, financial statements and internal audit working papers.
17 CFR 275.204-2(a)(6); kept 5 years under 17 CFR 275.204-2(e)(1)

Communications and agreements (2)

Written communications. Originals received and copies sent relating to recommendations and advice, receipt or delivery of funds or securities, the placing of orders, and performance.
17 CFR 275.204-2(a)(7); kept 5 years under 17 CFR 275.204-2(e)(1)
Written agreements. All written agreements entered into with any client or otherwise relating to the advisory business.
17 CFR 275.204-2(a)(10); kept 5 years under 17 CFR 275.204-2(e)(1)

Brochures and Form CRS (3)

Brochures, supplements and Form CRS. Each brochure, brochure supplement and Form CRS, every amendment, any separate summary of material changes, and the dates each was given to a client.
17 CFR 275.204-2(a)(14)(i); kept 5 years under 17 CFR 275.204-2(e)(1)
Managed-assets method. Documentation of the method used to compute managed assets for Item 4.E of Part 2A.
17 CFR 275.204-2(a)(14)(ii); kept 5 years under 17 CFR 275.204-2(e)(1)
Disciplinary-event memorandum. A memorandum explaining why the presumption of materiality is overcome for a legal or disciplinary event.
17 CFR 275.204-2(a)(14)(iii); kept 5 years under 17 CFR 275.204-2(e)(1)

Code of ethics (6)

Code of ethics. A copy of the code of ethics in effect, or at any time within the past five years in effect.
17 CFR 275.204-2(a)(12)(i); kept 5 years under 17 CFR 275.204-2(a)(12)(i), (a)(17)(i)
Code violations and actions taken. A record of any violation of the code of ethics, and of any action taken as a result.
17 CFR 275.204-2(a)(12)(ii); kept 5 years under 17 CFR 275.204-2(e)(1)
Acknowledgments of the code. All written acknowledgments for each person who is, or within the past five years was, a supervised person.
17 CFR 275.204-2(a)(12)(iii); kept 5 years under 17 CFR 275.204-2(a)(12)(iii), (a)(13)(ii)
Access-person reports. A record of each report made by an access person under Rule 204A-1(b).
17 CFR 275.204-2(a)(13)(i); kept 5 years under 17 CFR 275.204-2(e)(1)
List of access persons. The names of persons who are, or within the past five years were, access persons.
17 CFR 275.204-2(a)(13)(ii); kept 5 years under 17 CFR 275.204-2(a)(12)(iii), (a)(13)(ii)
Pre-approval decisions. Each decision, and the reasons for it, to approve an access person's acquisition of securities under Rule 204A-1(c).
17 CFR 275.204-2(a)(13)(iii); kept 5 years under 17 CFR 275.204-2(a)(13)(iii)

Compliance program (3)

Compliance policies and procedures. The policies and procedures under Rule 206(4)-7(a) in effect, or at any time within the past five years in effect.
17 CFR 275.204-2(a)(17)(i); kept 5 years under 17 CFR 275.204-2(a)(12)(i), (a)(17)(i)
Annual review records. Any records documenting the annual review of those policies and procedures.
17 CFR 275.204-2(a)(17)(ii); kept 5 years under 17 CFR 275.204-2(e)(1)
Internal control report. A copy of any internal control report obtained or received under Rule 206(4)-2(a)(6)(ii).
17 CFR 275.204-2(a)(17)(iii); kept 5 years under 17 CFR 275.204-2(e)(1)

Customer information (Regulation S-P) (4)

Safeguards policies. The written policies and procedures adopted under Regulation S-P, 17 CFR 248.30(a)(1).
17 CFR 275.204-2(a)(25)(i); kept 5 years under 17 CFR 275.204-2(e)(1)
Incident and notification records. Documentation of any detected unauthorized access to customer information, the response and recovery, and the investigation and determination on notice.
17 CFR 275.204-2(a)(25)(ii)-(iii); kept 5 years under 17 CFR 275.204-2(e)(1)
Service-provider policies and contracts. The service-provider oversight policies under 248.30(a)(5)(i) and the contracts entered into under 248.30(a)(5).
17 CFR 275.204-2(a)(25)(iv)-(v); kept 5 years under 17 CFR 275.204-2(e)(1)
Disposal policies. The written disposal policies and procedures under 248.30(b)(2).
17 CFR 275.204-2(a)(25)(vi); kept 5 years under 17 CFR 275.204-2(e)(1)

Firm documents (1)

Charters and minute books. Partnership articles and amendments, articles of incorporation, charters, minute books and stock certificate books, of the firm and any predecessor.
17 CFR 275.204-2(e)(2); kept 3 years under 17 CFR 275.204-2(e)(2)

Discretionary accounts (2)

List of discretionary accounts. A list or other record of all accounts in which the adviser is vested with any discretionary power.
17 CFR 275.204-2(a)(8); kept 5 years under 17 CFR 275.204-2(e)(1)
Powers of attorney. All powers of attorney and other evidence of discretionary authority granted by any client.
17 CFR 275.204-2(a)(9); kept 5 years under 17 CFR 275.204-2(e)(1)

Custody of client funds or securities (5)

Custody journal. A journal or other record of all purchases, sales, receipts and deliveries of securities (with certificate numbers) and all other debits and credits for those accounts.
17 CFR 275.204-2(b)(1); kept 5 years under 17 CFR 275.204-2(e)(1)
Separate client ledgers. A separate ledger account for each such client, with the date and price of each purchase and sale.
17 CFR 275.204-2(b)(2); kept 5 years under 17 CFR 275.204-2(e)(1)
Confirmations. Copies of confirmations of all transactions effected by or for the account of any such client.
17 CFR 275.204-2(b)(3); kept 5 years under 17 CFR 275.204-2(e)(1)
Position record by security. For each security, the clients with an interest in it, the amount of each interest, and where the security is held.
17 CFR 275.204-2(b)(4); kept 5 years under 17 CFR 275.204-2(e)(1)
Operational-independence memorandum. A memorandum describing the basis for overcoming the presumption that a related person is not operationally independent.
17 CFR 275.204-2(b)(5); kept 5 years under 17 CFR 275.204-2(e)(1)

Portfolio management (1)

Client purchase and sale records. For each client, the securities purchased and sold, with the date, amount and price of each.
17 CFR 275.204-2(c)(1)(i); kept 5 years under 17 CFR 275.204-2(e)(1)

Proxy voting (5)

Proxy voting policies. Copies of all policies and procedures required by Rule 206(4)-6.
17 CFR 275.204-2(c)(2)(i); kept 5 years under 17 CFR 275.204-2(e)(1)
Proxy statements. A copy of each proxy statement received regarding client securities; the rule allows a third party with an undertaking, or EDGAR.
17 CFR 275.204-2(c)(2)(ii); kept 5 years under 17 CFR 275.204-2(e)(1)
Record of each vote. A record of each vote cast on behalf of a client; the rule allows a third party with an undertaking.
17 CFR 275.204-2(c)(2)(iii); kept 5 years under 17 CFR 275.204-2(e)(1)
Voting decision documents. Any document created by the adviser that was material to a voting decision or memorializes its basis.
17 CFR 275.204-2(c)(2)(iv); kept 5 years under 17 CFR 275.204-2(e)(1)
Client voting requests. Each written client request for how the adviser voted, and any written response.
17 CFR 275.204-2(c)(2)(v); kept 5 years under 17 CFR 275.204-2(e)(1)

Advertising (3)

Each advertisement. A copy of each advertisement disseminated, directly or indirectly; for oral advertisements, the written or recorded materials used.
17 CFR 275.204-2(a)(11)(i)(A); kept 5 years under 17 CFR 275.204-2(e)(3)(i)
Communications to ten or more persons. Each notice, circular, newspaper article, investment letter, bulletin or other communication disseminated to ten or more persons outside the firm.
17 CFR 275.204-2(a)(11)(i)(B); kept 5 years under 17 CFR 275.204-2(e)(3)(i)
Reasons memorandum. A memorandum of the reasons for a specific-security recommendation that the communication does not state.
17 CFR 275.204-2(a)(11)(i)(C); kept 5 years under 17 CFR 275.204-2(e)(3)(i)

Performance (2)

Performance backup. All accounts, books, internal working papers and other records needed to form the basis for or demonstrate any performance or rate of return presented.
17 CFR 275.204-2(a)(16); kept 5 years under 17 CFR 275.204-2(e)(3)(i)
Intended-audience record. A record of who the intended audience is under Rule 206(4)-1(d)(6) and (e)(10)(ii)(B).
17 CFR 275.204-2(a)(19); kept 5 years under 17 CFR 275.204-2(e)(1)

Testimonials, endorsements and third-party ratings (4)

Rating questionnaire or survey. A copy of any questionnaire or survey used to prepare a third-party rating in an advertisement.
17 CFR 275.204-2(a)(11)(ii); kept 5 years under 17 CFR 275.204-2(e)(3)(i)
Testimonial and endorsement disclosures. A record of the disclosures provided under Rule 206(4)-1(b)(1)(ii) and (iii), if not included in the advertisement.
17 CFR 275.204-2(a)(15)(i); kept 5 years under 17 CFR 275.204-2(e)(1)
Reasonable-basis documentation. Documentation of the reasonable basis for believing a testimonial, endorsement or third-party rating complies with Rule 206(4)-1.
17 CFR 275.204-2(a)(15)(ii); kept 5 years under 17 CFR 275.204-2(e)(1)
Affiliated promoters. The names of the partners, officers, directors, employees and affiliates covered by Rule 206(4)-1(b)(4)(ii).
17 CFR 275.204-2(a)(15)(iii); kept 5 years under 17 CFR 275.204-2(e)(1)

Government entity clients (4)

Covered associates. The names, titles and business and residence addresses of all covered associates.
17 CFR 275.204-2(a)(18)(i)(A); kept 5 years under 17 CFR 275.204-2(e)(1)
Government entity clients. All government entities advised, or invested in a covered investment pool advised, in the past five years.
17 CFR 275.204-2(a)(18)(i)(B); kept 5 years under 17 CFR 275.204-2(e)(1)
Contributions and payments. All direct or indirect contributions to officials of a government entity and payments to parties or PACs, in chronological order.
17 CFR 275.204-2(a)(18)(i)(C), (a)(18)(ii); kept 5 years under 17 CFR 275.204-2(e)(1)
Paid solicitors. The name and business address of each regulated person paid to solicit a government entity for the adviser.
17 CFR 275.204-2(a)(18)(i)(D); kept 5 years under 17 CFR 275.204-2(e)(1)

Broker-dealers: Rules 17a-3, 17a-4 and FINRA rules

Blotters, ledgers and positions (5)

Blotters. An itemized daily record of all purchases and sales, receipts and deliveries of securities, receipts and disbursements of cash, and all other debits and credits.
17 CFR 240.17a-3(a)(1); kept 6 years under 17 CFR 240.17a-4(a)
General ledgers. Ledgers reflecting all assets and liabilities, income and expense and capital accounts.
17 CFR 240.17a-3(a)(2); kept 6 years under 17 CFR 240.17a-4(a)
Customer account ledgers. Ledger accounts itemizing separately each cash, margin or security-based swap account of every customer and of the firm.
17 CFR 240.17a-3(a)(3); kept 6 years under 17 CFR 240.17a-4(a)
Supporting ledgers. Securities in transfer, dividends and interest received, securities and money borrowed and loaned, fails to receive and deliver, record differences, repurchase agreements.
17 CFR 240.17a-3(a)(4); kept 3 years under 17 CFR 240.17a-4(b)
Securities record. A securities record or ledger showing separately, for each security, all long and short positions carried by the firm.
17 CFR 240.17a-3(a)(5); kept 6 years under 17 CFR 240.17a-4(a)

Orders, confirmations and accounts (9)

Order memoranda. A memorandum of each brokerage order and any other instruction, executed or unexecuted, with its terms, times and any modification.
17 CFR 240.17a-3(a)(6); kept 3 years under 17 CFR 240.17a-4(b)
Confirmations. Copies of confirmations of all purchases and sales, and notices of all other debits and credits.
17 CFR 240.17a-3(a)(8); kept 3 years under 17 CFR 240.17a-4(b)
Beneficial owner records. For each cash, margin and security-based swap account, the name and address of the beneficial owner and, for margin accounts, the owner's signature.
17 CFR 240.17a-3(a)(9); kept 3 years under 17 CFR 240.17a-4(b)
Guarantees and powers of attorney. All guarantees of accounts, powers of attorney and other evidence of discretionary authority, and resolutions empowering an agent of a corporation.
17 CFR 240.17a-4(b)(6); kept 3 years under 17 CFR 240.17a-4(b)
Written agreements. All written agreements relating to the firm's business, including agreements with respect to any account.
17 CFR 240.17a-4(b)(7); kept 3 years under 17 CFR 240.17a-4(b)
Account opening and terms records. Account cards or records relating to the terms and conditions of opening and maintaining a customer's account.
17 CFR 240.17a-4(c); kept 6 years under 17 CFR 240.17a-4(c)
Customer account information. For each account: name and residence, legal age, the responsible associated person, the accepting principal's signature, and a trusted contact person (not for institutional accounts).
FINRA Rule 4512(a); kept 6 years under FINRA Rule 4512.01
Complaint record. As to each associated person, each written customer complaint received concerning that person.
17 CFR 240.17a-3(a)(18)(i); kept 3 years under 17 CFR 240.17a-4(b)
Complaint-notice record. A record that each customer was given the address and telephone number of the department that takes complaints.
17 CFR 240.17a-3(a)(18)(ii); kept 3 years under 17 CFR 240.17a-4(b)

Financial records (4)

Trial balances and net capital. A record of the proof of money balances in trial balances, and the computation of aggregate indebtedness and net capital.
17 CFR 240.17a-3(a)(11); kept 3 years under 17 CFR 240.17a-4(b)
Check books and bank records. All check books, bank statements, cancelled checks and cash reconciliations.
17 CFR 240.17a-4(b)(2); kept 3 years under 17 CFR 240.17a-4(b)
Bills receivable or payable. All bills receivable or payable, paid or unpaid, relating to the firm's business.
17 CFR 240.17a-4(b)(3); kept 3 years under 17 CFR 240.17a-4(b)
Financial statements and audit papers. Financial statements, branch office reconciliations and internal audit working papers, with net capital working papers.
17 CFR 240.17a-4(b)(5); kept 3 years under 17 CFR 240.17a-4(b)

Communications (2)

Communications sent and received. Originals of all communications received and copies of all sent, with any approvals, including inter-office memoranda, relating to the business; FINRA Rule 3110.09 keeps associated persons' correspondence for the same period.
17 CFR 240.17a-4(b)(4); FINRA Rule 3110.09; kept 3 years under 17 CFR 240.17a-4(b)
Principal-approval record. A record documenting compliance with the requirement that communications with the public be approved by a principal.
17 CFR 240.17a-3(a)(20); kept 3 years under 17 CFR 240.17a-4(b)

Associated persons and compensation (4)

Questionnaires or applications. A questionnaire or application for employment executed by each associated person and approved in writing.
17 CFR 240.17a-3(a)(12)(i); kept 3 years under 17 CFR 240.17a-4(e)(1)
Associated-person office list. A record listing every associated person and every office where each regularly conducts business.
17 CFR 240.17a-3(a)(12)(ii); kept 3 years under 17 CFR 240.17a-4(e)(1)
Compensation record. As to each associated person, each purchase and sale attributable to that person for compensation purposes, with the compensation.
17 CFR 240.17a-3(a)(19)(i); kept 3 years under 17 CFR 240.17a-4(b)
Associated-person agreements. All agreements with each associated person, including a summary of the person's compensation arrangement.
17 CFR 240.17a-3(a)(19)(ii); kept 3 years under 17 CFR 240.17a-4(b)

Offices, principals and supervision (3)

Office records contact list. For each office, each person who can explain the types of records kept there and the information in them.
17 CFR 240.17a-3(a)(21); kept 6 years under 17 CFR 240.17a-4(a)
Responsible principals list. Each principal responsible for establishing compliance policies and procedures.
17 CFR 240.17a-3(a)(22); kept 6 years under 17 CFR 240.17a-4(a)
Supervisory designations. The record of the firm's supervisory designations.
FINRA Rule 3110(b)(6); kept 3 years under FINRA Rule 3110(b)(6)

Manuals, reports and examinations (3)

Compliance and supervisory manuals. Each compliance, supervisory and procedures manual, with every update, modification and revision.
17 CFR 240.17a-4(e)(7); kept 3 years under 17 CFR 240.17a-4(e)(7)
Regulator reports and exam reports. Each report a regulator required under an order or settlement, and each examination report.
17 CFR 240.17a-4(e)(6); kept 3 years under 17 CFR 240.17a-4(e)(6)
Unusual-activity reports. All reports produced to review for unusual activity in customer accounts; the firm may instead produce them promptly on request.
17 CFR 240.17a-4(e)(8); kept 18 months under 17 CFR 240.17a-4(e)(8)

Customer information (Regulation S-P) (2)

Safeguards policies. The written policies and procedures adopted under Regulation S-P, 17 CFR 248.30(a)(1).
17 CFR 240.17a-4(e)(14)(i); kept 3 years under 17 CFR 240.17a-4(e)(14)(i)
Incident and notification records. Documentation of any detected unauthorized access to customer information, the response and recovery, and the investigation and determination on notice.
17 CFR 240.17a-4(e)(14)(ii)-(iii); kept 3 years under 17 CFR 240.17a-4(e)(14)(ii)-(iii)

Firm documents (1)

Charters, minute books and Forms BD. Partnership articles or charters, minute books, stock certificate books, all Forms BD and BDW, and licenses.
17 CFR 240.17a-4(d); kept life of the firm under 17 CFR 240.17a-4(d)

Natural-person and retail customers (5)

Natural-person account record. For each account with a natural person as customer or owner: the account record and the records of furnishing it to the customer.
17 CFR 240.17a-3(a)(17)(i); kept 6 years under 17 CFR 240.17a-4(e)(5)
Agreement-delivery record. For each account, a record that the customer was furnished a copy of each written agreement for that account.
17 CFR 240.17a-3(a)(17)(iii); kept 6 years under 17 CFR 240.17a-4(e)(5)
Form CRS and delivery dates. A record of the date each Form CRS was provided to each retail investor, and a copy of each Form CRS.
17 CFR 240.17a-3(a)(24); 17 CFR 240.17a-4(e)(10); kept 6 years under 17 CFR 240.17a-4(e)(10)
Regulation Best Interest record. All information collected from and provided to the retail customer under Rule 15l-1, and the associated person responsible for the account.
17 CFR 240.17a-3(a)(35)(i); kept 6 years under 17 CFR 240.17a-4(e)(5)
Discretionary authority signatures. For a discretionary account, the dated signature of each customer granting the authority and of each person given it.
17 CFR 240.17a-3(a)(17)(ii); kept 6 years under 17 CFR 240.17a-4(e)(5)

Trading for the firm's own account (2)

Proprietary trade memoranda. A memorandum of each purchase or sale for the firm's own account, with the price and, where feasible, the time of execution.
17 CFR 240.17a-3(a)(7); kept 3 years under 17 CFR 240.17a-4(b)
Options record. All puts, calls, spreads, straddles and other options in which the firm has an interest or which it granted or guaranteed.
17 CFR 240.17a-3(a)(10); kept 3 years under 17 CFR 240.17a-4(b)

Retail and institutional communications (1)

Retail and institutional communications. Each communication with the dates of first and last use, the approving principal and approval date, and the source of any statistical table, chart or graph.
FINRA Rule 2210(b)(4)(A); kept 3 years under FINRA Rule 2210(b)(4)(A); 17 CFR 240.17a-4(b)

The where-kept column is where software comes in. Communications rows are usually the largest by volume; the comparisons of email archiving software and SEC 17a-4 compliant storage read vendors against these rules, and RIA compliance software covers the code-of-ethics and annual-review rows. The customer-information rows are explained in the Regulation S-P guide.

Books and records checklist generator

Records checklist: the tool

Accounts and financial records

Communications and agreements

Brochures and Form CRS

Code of ethics

Compliance program

Customer information (Regulation S-P)

Firm documents

Discretionary accounts

Portfolio management

Advertising