SEC and State RIA Examination Preparation Document Request Checklist

It covers the core document groups examiners typically request from a registered investment adviser: scope and request tracking, governance and registration records, compliance program evidence, client agreements and disclosures, trading and custody support, and supervised person training and remediation. The checklist is designed to help you gather what is already expected to exist in the firm’s books and records. It is not a substitute for legal advice or a formal exam response strategy, but it gives you a structured working file for the exam cycle.

A compliance officer, general counsel, or designated exam coordinator should own the checklist, with input from operations, trading, finance, and advisory teams. The template works best when one person manages the request log and assigns evidence collection to subject-matter owners. That keeps responses consistent and reduces the risk of duplicate, late, or conflicting submissions.

Use it as soon as an exam notice or request letter arrives, then keep it active through the full response period and any follow-up requests. Many firms also reuse it for internal mock exams or annual readiness reviews so the evidence set stays current. If your firm has frequent amendments, new products, or custody-related changes, it is worth refreshing the checklist more often than once a year.

Yes, it is built for either SEC or state registered investment adviser examinations, with sections that map to the records and controls both regulators commonly review. The exact request list will vary by regulator, firm size, custody status, and business model. You should tailor the checklist to the exam notice, your state requirements, and any specialized activities such as performance advertising or custody.

A common mistake is treating the request as a document dump instead of a controlled response with owners, due dates, and status tracking. Firms also miss gaps between what is written in policies and what is actually supported by evidence, such as incomplete annual reviews or missing fee calculation support. Another frequent issue is sending outdated Form ADV, stale disclosures, or records that are not organized in a way the examiner can follow.

It gives you a place to identify where core records are stored and confirm that the supporting evidence is retrievable before the examiner asks for it. That matters because examiners often test whether records are complete, current, and easy to produce, not just whether they exist somewhere in the firm. The checklist also helps surface retention gaps in trade records, communications, complaints, and supervision files.

Yes, and you should. A firm with custody, performance-based fees, private funds, or a heavy marketing footprint will need more detailed evidence in those sections than a plain-vanilla advisory firm. You can add request rows, attach internal owners, and expand the custody, valuation, advertising, or supervision sections to match your actual risk profile.

Keep them in the checklist so you can show what was identified, who owns the fix, when it was completed, and what evidence proves closure. Examiners often look for whether prior deficiencies were remediated and whether the same issue has reappeared. A clean remediation trail is often as important as the original response.

Email and shared folders can store files, but they do not reliably show request ownership, due dates, status, or whether every item was answered with the right evidence. This template turns the response into a controlled workflow, which makes it easier to see missing items and avoid last-minute scrambling. It also creates a clearer audit trail if the regulator asks how the response was assembled.