Not legal advice. Review with counsel. This is a general checklist built from the rule text and SEC staff observations. It does not tell you what your firm specifically must do. Last checked against sources: October 21, 2026.
| # | For | Step | Why (source) |
|---|
A planning suggestion, not a regulatory deadline. The rules require "no less frequently than annually" (RIA) or a certification "annually" (BD); neither sets a calendar date. The SEC staff flagged reviews covering more than 12 months.
| When | What |
|---|---|
| Week 1 | Set the review period (12 months, contiguous with last year's). Pull last year's report and open items. |
| Weeks 2-4 | Test each policy area; collect evidence in the log below. |
| Week 5 | List findings with owners and due dates. Update policies where practice has changed. |
| Week 6 | Write and date the report. RIA: present it to senior management. BD: CEO-CCO meeting(s), then the Rule 3130 certification. |
| Ongoing | Track corrective actions to closure, and do interim reviews after significant events. |
Print this blank, or download the CSV and fill it in a spreadsheet. Keep it with your books and records.
| Area / policy | Test performed | Evidence (file / location) | Finding | Corrective action | Owner | Due | Closed |
|---|---|---|---|---|---|---|---|
State-registered advisers: Rule 206(4)-7 applies to SEC-registered advisers. Check your state's rules.