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RIA — ADV / Form CRS Compliance Checklist

Activate when: annual ADV amendment season; onboarding/updating Form CRS delivery; launching marketing/testimonials; a mock/real exam; 'are we books-and-records compliant?', 'can we post this ad/testimonial?'. Do NOT activate when: the question is portfolio construction, not compliance.

deciqAI@deciqai

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openclaw skills install @deciqai/ria-adv-crs-compliance-checklist

RIA — ADV / Form CRS Compliance Checklist

Industry front door for checklist. Adds domain triggers, example, packs only. Parent Process unchanged. Not legal or compliance advice. Verify against current SEC/state rules and your CCO before filing or publishing.

Activate when: annual ADV amendment season; onboarding/updating Form CRS delivery; launching marketing/testimonials; a mock/real exam; "are we books-and-records compliant?", "can we post this ad/testimonial?" Do NOT activate when: the question is portfolio construction, not compliance.

Why this variant

The parent checklist converts "are we covered?" into a verifiable gate. RIA regulation is a set of recurring, penalty-backed gates (ADV update, CRS delivery, Marketing Rule, Custody, Books & Records). This maps those obligations onto the parent's gate discipline.

Domain inputs → parent's gate

Checklist items (state/SEC as applicable):

  • ADV Part 1/2A/2B annual amendment within 90 days of fiscal year-end; material-change interim updates.
  • Form CRS delivered to retail clients at/before engagement; filed; posted.
  • Marketing Rule (206(4)-1, 2021): testimonials/endorsements disclosed & overseen; no cherry-picked performance; substantiation on hand.
  • Custody Rule 206(4)-2: qualified custodian, account statements, surprise exam if deemed custody.
  • Books & Records 204-2: required records retained (generally 5 yrs, first 2 easily accessible).
  • Reg S-P privacy notice; Code of Ethics 204A-1; AML as applicable.

Worked example

Advisor wants to post a client testimonial on the website. → Gate: Marketing Rule requires disclosures (whether compensated, material conflicts), advisor oversight, and records. Missing disclosure = fail → do not publish until the item clears.

Compliance anchors

  • Advisers Act Rules 204-2, 204A-1, 206(4)-1, 206(4)-2; Reg S-P; Form ADV & CRS instructions.

Packs

  • Solo/small RIA: annual compliance calendar tied to fiscal year-end.
  • CCO: exam-ready evidence binder per rule; testing log.

Red flags

  • ADV past the 90-day window.
  • Testimonial/ad without required disclosures or records.
  • "Deemed custody" via SLOAs not assessed.

Verification

  • ADV amended within 90 days; interim material changes filed
  • Form CRS delivered/filed/posted
  • Marketing pieces disclosure-checked & recorded
  • Custody status assessed
  • Books & records retention confirmed

Part of deciqAI Knowledge Skills. Core method: checklist.

Part of deciqAI Knowledge Skills — 189 open-source thinking skills that make rigor executable for AI agents. The same skills power every deciqAI agent, which runs them autonomously to operate your company. See it run → https://www.deciqai.com/c/ria-adv-crs-compliance-checklist · ⭐ Star the repo → https://github.com/deciqAI/knowledge-skills · Contributions welcome.