Client File Guidelines
From Planipedia
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Document Collection – The foundational aspect of the planning process is the collection of the appropriate documentation to support the assumptions and current situation of your client. The ideal documentation that you require will be largely dependent upon the type of service and planning you are providing to your client. Note that in addition to these documents, appropriate discussions about goals, objectives, attitudes and priorities are also critical. These discussions are best conducted using a formal Fact-Finding Questionnaire.
| Service Provided | Documentation to Retain on File |
|---|---|
| Investment planning |
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| Retirement planning |
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| Education planning |
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| Cash & tax planning |
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| Risk management |
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| Estate planning |
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File Segmentation, Contents and Storage Location – Below is an example of how files can be segmented and arranged to allow efficient access. This example can be your starting point and you can customize from this point to make it suitable to your situation.
| File Name | File Contents | Storage Location |
|---|---|---|
| Client Service File |
This file will hold all documents that pertain to current tasks being undertaken for this client. The layout of the contents of this file is as follows:
| Advisors office – Since this file will be referred to most frequently, it should be stored in the advisors office.
In this way, if your client calls, you can access the file quickly and have all pertinent information regarding current issues of concern at your fingertips. For security purposes, these files should be stored in a locked file drawer. |
| Financial Planning File |
This file will contain most of the source documents used in developing the plan for the date indicated on the label. All materials should be two-hole punched on the left margin and fastened in the file using an Acco fastener. These documents will include the following:
Financial planning report – A copy of the completed plan is to be left loose in the file with either a clamp on the document or stapled. General correspondence relating to the planning process – Copies of all correspondence should be filed in chronological order with the most recent on top. This should be fastened to the back of the file (on top of the data collection materials). File label & colour coding – Below is an illustration of the file folder label that will be used for this file. Either the file folder label or the file folder itself should be colour-coded GREEN to distinguish this file clearly from other files. Historical filing – When a review plan is completed, a new file should be set up with the current date indicated. The previous plan will be retained in it’s own file and kept in main client filing cabinets along with the current plan so that at all time we’ll have two consecutive plans at our fingertips. Once a file is into its second review, the original or first planning file may be removed and go into historical off-site storage. It will be our practice to retain historical files for seven years at which time these old files will be destroyed. |
Central filing – This file may be retained in a central filing system where it can be accessed on an as-needed basis. Given that the Client Service File holds copies of the action plan and other current issues, this file will not need to be referenced too often once the current plan has been presented and implementation has commenced. These files should be maintained in locked storage facilities for security purposes. |
| Tax Returns File | This file will be used to maintain copies of the client’s Tax Returns and Notices of Assessment. You may alternatively elect to save the tax returns in the Financial Planning file.
File label & colour coding – Below is an illustration of the file folder label that will be used for this file. Either the file folder label or the file folder itself should be colour-coded BLUE to distinguish this file clearly from other files. | Central filing – Once the current plan has been completed, access to tax returns may not be required very frequently and thus central storage provides adequate access.
These files should be maintained in locked storage facilities for security purposes. |
| Product Files | In addition to the planning files referred to above, there will be compliance requirements, which indicate the file location, contents, and format that are required for various products. For example, securities regulations have strict compliance requirements, as do insurance standards. For this reason, appropriate product files would need to be set up for the client given their product transactions.
Given that the content of these product files are governed by compliance regulations, we will not review their contents here but rather will just acknowledge that these files must exist where product transactions have taken place. | Central filing – These files may be retained in a central filing system where it can be accessed on an as-needed basis. Compliance regulations will dictate the security required, such as locked cabinets, secured filing rooms, etc. |
| Electronic Client Relationship File | Paper vs. electronic – It’s been an objective for many years to minimize the paper-based storage of client information in favour of more efficient electronic data storage. However, it’s still a reality that paper-based documentation is very necessary, unless you have sophisticated document imaging systems that can capture paper-based information and store it electronically. That being said, there are electronic client relationship management software packages on the market that can assist in the collection, retention, and organization of a large variety of client data, e.g., GoldMine. All have different features, but do have a common theme, i.e., giving you quick electronic access to relevant client data.
Some of the aspects of electronic data collection that represent a best practice include client meeting notes. Retaining a written summary of any meetings held with your clients on an electronic system can be valuable from a number of perspectives. It helps you to recall conversations, decisions, and action items that result from your client face-to-face and telephone meetings. By making it a practice to have your client receive copies of these meeting notes and signing off on their content ensures you are protected from possible later client misunderstandings. Taping meetings and attaching digital audio files to the client’s electronic file can be reviewed at a later date should it become necessary. | Electronic data storage requires comprehensive security features to protect data from being viewed by external and even internal people who have no direct responsibility for the client’s affairs. |
In Conclusion – These guidelines provide a comprehensive overview of the maintenance of client documents in both your paper-based and electronic data files. Once you have created your own guidelines, ensuring adherence to those guidelines becomes a matter of discipline since it’s always easy to let these kinds of procedures slip when you are busy or in a rush.
