How to manage books and records in SmartRIA

There are various ways SmartRIA leverages automation and compliant-file storage to help firms manage their books and records.

This article covers file storage, self-audit checklists and workflows as they relate to books and records.

Background on SmartRIA Document Storage

In the U.S., we pre-populate file folder structure based on books and records rule 204-2. We also have an additional level of storage for advisors. Our robust search capability and reports make it easy to find documentation. The organization and structure can be utilized and customized to best suit your firm's needs.

Document and File Storage Levels

  • Company Shared Files - where policies, manuals, templates to be viewed by all employees reside
  • Management | CCO Files - documents accessible only by CCO and anyone CCO has designated on their compliance team
  • Client Files - files specific to a client, such as Client Investment Objectives
  • Account Files - files specific to an account, such as account agreements
  • Advisor Files - Individual file storage for advisors. These files are visible to the advisor and compliance team only

(The default folder structures for Company, Management, and Client files can be viewed here.)

SmartRIA Data Retention

Data is currently retained permanently. We plan to make this configurable at the company level so that retention length can be set by document type.

Designating Responsible Parties to Maintain Books and Records

Using SmartRIA's workflows, firms can designate individuals to review, update, and document changes to required books and records documents. For example, the VP of Finance could be assigned the task to review and update the company's billing records. The records can be stored within the system, and easily updated or archived depending on relevancy.

Using Workflows to Capture Required Records

Workflows in SmartRIA can be used to capture a variety of required records. This method allows firms to utilize powerful reporting options to quickly find and extract necessary information for reporting purposes. Some examples include:

  • New employee workflows for Initial Holdings Reports and Employee Contracts
  • Quick access form workflows to capture Client Complaints and document resolutions
  • Trade Monitoring - Quarterly Transaction Report workflows to capture employee transactions and compare to the firm's Code of Ethics
  • Annual Compliance Questionnaire workflow to capture important employee updates on an annual basis

Books and Records Self-Audit Checklist

In addition to compliant-file storage, SmartRIA also offers a template Books and Records self-audit checklist, designed to help you review your policies, storage methods and more. This checklist can be updated and configured for your firm based on your firm structure and needs. This checklist also allows you to upload relevant documentation that you have discovered during your review. A snippet of 2 of the questions is below.

SmartRIA Default Folders

Below is the default structure, modeled after Advisers Act Rule 204-2. These structures can be further customized by the CCO.

Company Shared Files

For policies, manuals, templates to be viewed by all employees

Main Folder Sub Folder
> Blog Postings
> Brochures
> Print advertising
> Radio and TV scripts
> Seminars
> Social Media
> Website content
Compliance Policies  
> Code of ethics
> Compliance Manual
> Cybersecurity
> Disaster recovery
> Blank Contracts
> Privacy
> Suitability Forms
> Template Letters
> Memos
> PowerPoints
> Staff Checklists
> Videos

Management | CCO Files

Documents accessible only by CCO and anyone CCO has designated on their compliance team

Main Folder Sub Folder Main Folder Sub Folder
Form Uploads   Financials  
Branches     > Balance sheet
> Branch ADV  > Bills and Statements
> Branch advertising  > Check logs and ledgers
> Branch Policies  Human Resources  
Compliance    > Employee files
> ADV archive  > Master HR documents
> Advertising reviews  Investments  
> Agreement to abide by manual  > Best execution
> Complaints  > Proxies
> Disaster recovery test  > Research
> Misc forms > Soft dollars 
> Policies archive  > Sub-advisors and TPA
> Registrations  > Trade blotters
> Solicitor Docs  > Trade errors
Calendar   Tasks  
Corporate   > CCO Checklists 
> Corporate docs  > COE Reports 
> Custodial agreements  > IAR questionnaires 
> Non-Client correspondence  > OBA questionnaires 
> Vendors  > Social media reporting 

Client Files

Files specific to a client, such as Client Investment Objectives

Main Folder Sub Folder
Required Docs  
> Client Letters Received
> Client Letters Sent
> Invoices
> Reports
> Statements
Financial Planning  
> Education
> Estate
> Insurance
> Investments
> Retirement
> Taxes