Free checklist · for financial advisors

New-client
onboarding checklist.

Onboarding is where a new client decides whether you're organized. This list covers what to deliver, collect and sign — roughly in the order it happens — with notes where RIAs and broker-dealers differ.

RIA or broker-dealer?
Know which rules you're under

RIA or broker-dealer: the short version.

Dual registrants follow both columns, depending on the capacity they're acting in.

Broker-dealer repsRegistered investment advisers
StandardRegulation Best Interest for recommendations to retail customers: disclosure, care, conflict-of-interest and compliance obligations5Fiduciary duty, including a reasonable inquiry into the client's financial situation, sophistication, experience and goals9
Form CRSBefore or at the earliest of a recommendation, an order, or opening an account6Before or at the time the advisory contract is signed7
Other disclosuresReg BI disclosures before or at the time of the recommendation5Form ADV Part 2A brochure before or at signing; Part 2B supplement before that person starts advising8
Account rulesFINRA Rules 2090 (know your customer) and 4512 (account information); customer identification program1,2,4Your custodian's account opening and identity checks; FinCEN's anti-money-laundering rule for advisers is delayed to January 1, 202813
PrivacyRegulation S-P: a privacy notice no later than when the relationship starts; the 2024 amendments add an incident-response program and customer notice within 30 days of certain breaches (compliance dates have passed)10,11,12

1 · Deliver before or at the start

2 · Identity and account basics

3 · The investment profile

Reg BI's list; an RIA's reasonable inquiry covers the same ground.5,9

4 · Agreements and account forms

5 · Beneficiaries

6 · The plan and the first review

Clients 65 and older: FINRA Rule 2165 lets member firms place a temporary hold when they reasonably believe a "specified adult" (65+, or 18+ with an impairment) is being financially exploited — the trusted contact you collected in step 2 is what makes that workable.3
General information, not legal or compliance advice. Follow your firm's, broker-dealer's or custodian's procedures; they may require more. Last checked October 10, 2026.

Sources

  1. FINRA Rule 2090, Know Your Customer. finra.org
  2. FINRA Rule 4512, Customer Account Information (trusted contact person). finra.org
  3. FINRA Rule 2165, Financial Exploitation of Specified Adults. finra.org
  4. 31 CFR §1023.220, customer identification programs for broker-dealers. ecfr.gov
  5. 17 CFR §240.15l-1, Regulation Best Interest. ecfr.gov
  6. 17 CFR §240.17a-14, Form CRS for broker-dealers. ecfr.gov
  7. 17 CFR §275.204-5, Form CRS for investment advisers. ecfr.gov
  8. 17 CFR §275.204-3, brochure delivery (Form ADV Part 2). ecfr.gov
  9. SEC Release IA-5248, Commission Interpretation Regarding Standard of Conduct for Investment Advisers (2019). sec.gov
  10. 17 CFR §248.4, Regulation S-P initial privacy notice. ecfr.gov
  11. SEC press release 2024-58, amendments to Regulation S-P (May 16, 2024). sec.gov
  12. SEC, "Enhancements to Regulation S-P: A Small Entity Compliance Guide" (compliance dates Dec 3, 2025 and June 3, 2026). sec.gov
  13. FinCEN, "Delaying the Effective Date of the Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers," Federal Register (Jan 2, 2026). federalregister.gov
  14. CFA Institute, "Elements of an Investment Policy Statement for Individual Investors" (May 2010). cfainstitute.org
  15. FINRA, "Plan Now to Smooth the Transfer of Your Brokerage Account Assets on Death" (Jan 17, 2023). finra.org

Sources opened and checked October 10, 2026. Rules change — follow the links for the current text.

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