Financial advisor / regulated professional services
Independent RIAs, insurance brokers, financial planners, regulated wealth managers — fiduciary obligations, KYC + suitability gates, regulatory exam horizon, client annual-review cadence.
KYC · suitability · annual review · fiduciary documentation
What gets pre-loaded
preferenceimportance 9/10 Client communication — every recommendation references the suitability rationale, never the product
All client-facing recommendations (email, written plan, meeting agenda) lead with the suitability rationale ('your stated goal is X over horizon Y, your stated risk tolerance is Z, here's the recommendation that fits') rather than the product itself ('here's the recommendation, here's why it fits'). The lead matters because fiduciary review (client review, internal compliance, regulatory exam) tracks the rationale chain — a recommendation whose stated rationale is reverse-engineered after the product choice fails the suitability test even if the product itself is appropriate. Surface a watch item on any client-facing recommendation that doesn't lead with the suitability rationale.
preferenceimportance 10/10 KYC + suitability gate — every new account gets a fresh KYC + suitability before any recommendation
Every new account opened (and every existing account on annual review) gets a fresh Know-Your-Customer + suitability questionnaire BEFORE any recommendation flows through the relationship. The gate is non-negotiable — bypassing it for a long-tenure relationship or a referral introduction is the single largest source of suitability-violation findings in regulatory exams. Surface a watch item on any new account whose first recommendation predates the KYC + suitability return-date, and on any annual-review cycle that closes without a fresh suitability questionnaire.
lessonimportance 10/10 Annual-review cadence — every client touched within 13 months, no exceptions
Every advised client gets a substantive annual-review touch (in-person meeting, video call, or written plan update with explicit client acknowledgement) within 13 months of the prior annual review. The 13-month window allows for life events that delay the calendar review without breaking the regulatory expectation. Past the 13-month threshold the relationship reads as un-supervised in a regulatory exam regardless of relationship strength or client preference, and any recommendations flowing through the relationship are at fiduciary-violation risk. Surface a watch item the moment any advised client crosses 12 months since the prior annual review, with 30 days of buffer before the regulatory cliff.
lessonimportance 9/10 Suitability red flag — recommendation that requires explanation, not endorsement
Any recommendation a client cannot summarise back to the advisor in their own words after the meeting is a fiduciary risk — the recommendation is suitable on paper if the client understood the rationale, but is suitability-violation territory if the recommendation rests on the advisor's authority rather than the client's understanding. The pattern shows up most often on alternative investments, structured products, and complex insurance products. Surface a watch item on any recommendation whose client-readback doesn't restate the suitability rationale in the client's own words, and prompt the advisor to either re-explain or recommend a simpler instrument that the client can summarise back.
Sample signal seeded on day 1
Sample client question — concentration risk in a long-held position
Long-tenure client (12 years on the relationship, 73 years old, retired 4 years) just emailed asking 'I notice the position in [single-stock holding] is now 38% of the portfolio after this year's run — should we be doing something about that?' Worth flagging immediately and surfacing a watch item: this is exactly the shape of client-initiated suitability question that protects the advisor in any future regulatory exam *if* it gets a documented suitability response within 30 days. The right response isn't a phone call — it's a written response (email, letter, plan amendment) that names the concentration percentage, the client's stated risk tolerance, the trade-off in tax cost vs concentration risk, and a specific recommendation ('reduce by 50% over 18 months via systematic sales' or 'hold and monitor at quarterly checkpoints') with the client's signature acknowledgement. The client's question itself is the most valuable suitability artifact in the relationship — preserve it verbatim alongside the response in the client file.
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