Client Onboarding

The phases

1. Engagement — advisory agreement signed, fees disclosed, scope defined.
2. Disclosure delivery — Form CRS, Part 2A brochure, relevant Part 2B supplements, privacy notice.
3. Profile capture — KYC, financial situation, investment objectives, risk tolerance, time horizon.
4. IPS construction — formal investment policy statement signed by the client.
5. Account opening — custodian paperwork, beneficiary designations, transfer-on-death, ACATS for transfers.
6. Funding and initial allocation — assets received, initial portfolio constructed against the IPS.
7. Ongoing setup — billing schedule, performance reporting cadence, communication preferences.

What a defensible onboarding produces

• Timestamped delivery records for every required disclosure.
• A signed IPS matching the captured profile.
• A documented risk tolerance with both willingness and capacity captured.
• An initial portfolio that visibly aligns with the IPS.
• A documented suitability conversation, including specific high-risk products if any.

What examiners look for

The onboarding file is often the first thing pulled in an account-level review during an examination. The examiner wants to see that:

• Required disclosures were delivered before recommendations were made.
• The client's profile is current and complete.
• The IPS exists and matches the portfolio.
• Any complex products (private credit, buffer ETFs, leveraged strategies) have specific suitability documentation.

Common deficiencies

• Disclosures backdated or with no delivery timestamp.
• Profile fields blank or generic.
• IPS standardized to the point of not reflecting the actual client.
• Initial portfolio built before profile is complete.

How StratiFi thinks about client onboarding

Onboarding is the foundation. Every later decision — a rebalance, a recommendation, a complex-product addition — is judged against the baseline created at onboarding. Firms that hold up under examination treat onboarding as a connected workflow with discipline at every step, not a paperwork sprint to close the engagement.