RIA Books and Records Maintenance
A question every adviser asks when coming on board is: “As an RIA, What documents do I need to save and what documents can I dispose of, and when can I?” As a registered adviser, you are required to maintain certain books and records that pertain to your investment advisory business. This is rule 204-2 and is known as the “Books and Records Rule”. Here is a basic list of the books and records that need to be maintained by advisers that do not take custody or possession of client funds and securities.
Your RIA firms financial records
Investment Advice given to clients
Transactions affecting clients, correspondence sent or received from clients/prospects
Client agreements and contracts
Advertising and performance records (along with : Newsletters, articles, worksheets)
Code of Ethics files (example: access persons security transactions)
Maintenance and Delivery of disclosure documents. (include solicitor agreements)
Policies and Procedures (Compliance, Annual Reviews)
Generally, most books and records must be kept for five years from the last day of the fiscal year that the last entry was made on each document. After a two year time period advisers may opt to store these (originals) files in an alternative location. If an adviser decides to do this they must make the location known via the most recent ADV filing. Keep in mind that these records need to be accessible within 24 hours.