What examiners actually ask for

Published August 2026 · By the UltimateCRM team · Educational overview as of August 2026 — not legal, tax, or compliance advice. Confirm requirements with your compliance counsel.

How an exam starts

You get a call or letter from your regional office, then a initial document request list — often dozens of items with a deadline measured in weeks. Interviews and follow-up requests come later, but first impressions are formed by that first production: complete, organized, and on time reads as a firm in control; late and patchy invites deeper digging.

The typical request list, translated

• Who you are: Form ADV (all parts), organizational chart, ownership, affiliated entities, and any disciplinary history.
• Your compliance program: written policies and procedures (Rule 206(4)-7), your most recent annual review, the code of ethics, and personal-trading records for access persons.
• Your clients: a full client list with account types and fees, advisory agreements, fee schedules and billing records, and the suitability/KYC information supporting your advice — see how current those profiles need to be.
• Your trading: trade blotters for the exam period, best-execution reviews, allocation policies, and any principal or cross transactions.
• Your communications: email and, increasingly, text and chat records for selected custodians of the business — sometimes samples, sometimes "all communications for these ten clients."
• Your marketing: advertisements, performance claims, endorsements and testimonials with their Marketing Rule substantiation.
• Your money & operations: financials, custody arrangements and surprise-exam evidence if applicable, business-continuity plan, vendor due diligence, and cybersecurity policies.

What examiners are really testing

Item by item, the list checks rules. Taken together, it tests something simpler: does your operational reality match your paperwork? If your policies say communications are captured, they'll ask for a specific advisor's texts. If your ADV says annual reviews, they'll pick a household and ask for evidence. The firms that struggle aren't usually hiding anything — they just can't find things, because records live across five systems and two ex-employees' inboxes.

Being the fast firm

• Keep records where they're produced from. Every system you'd have to visit during an exam is a multiplier on response time.
• Run a mock request quarterly. Pick three list items above and time the retrieval. The gaps you find are free; the ones examiners find are not.
• Evidence the reviews themselves. Supervision and annual reviews only count if documented — sign-offs need timestamps and names.
• Watch your obligations, not your memory. KYC refreshes, attestations, and review cadences should surface themselves as work items, not live in a spreadsheet someone updates in December.

Where UltimateCRM helps

This is what the compliance side of UltimateCRM is for: communications (email, calendar, calls, texts) captured automatically and exportable per client or firm-wide; a versioned document register for policies and agreements with approval history; per-client KYC and attestation records; principal-review queues with documented sign-off; and a compliance worklist that derives obligations — like KYC refreshes — so the evidence exists before anyone asks. The compliance tour shows it end to end.