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How do I build a documentation system?

2 min read

Chapter 6: Building Your Documentation System

Knowing the requirements is different from implementing them. This chapter provides practical starting points for improving your documentation practices.

6.1 Your First Steps

First Steps

  1. Audit one client file this week. Pull a single file and review it against the KYC checklist in Chapter 2. Note the gaps. That's your roadmap for what needs improvement.

  2. Check your risk profile documentation. For that same client, verify that you have documented both risk tolerance AND risk capacity separately. Can you explain how the risk profile was determined?

  3. Review your last three recommendations. Look at your suitability documentation for each. Does it follow the memo format: profile, recommendation, rationale, alternatives, costs, disclosures?

  4. Identify your AI exposure. List any AI tools you use for business purposes. For each, answer the four evaluation questions. Which ones can your compliance team see?

Start small. One file. One audit. One improvement. Then repeat.

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6.2 Quality Checkpoints

How do you know your documentation is working? Check against these standards:

  • Can you reconstruct what you knew about the client at the time of any recommendation?
  • Can you explain why a recommendation suited the client without relying on memory?
  • If you left tomorrow, could another advisor understand your client from the file alone?
  • Would your documentation satisfy a CIRO examiner reviewing for reasonability?

If you can answer yes to these questions, your documentation is serving its purpose.

6.3 Integrating Into Daily Practice

Sustainable documentation comes from integrating it into workflow, not adding it as an afterthought:

  • Document at the point of action, not days later
  • Use templates for consistency (but customize for each client)
  • Set regular review intervals for existing clients
  • When in doubt, document the reasoning, not just the decision

CIRO Compliance Documentation Checklist

A downloadable PDF consolidating the key requirements from this guide:

  • KYC documentation requirements and update triggers
  • Suitability memo template and components
  • 7-year retention framework and format requirements
  • AI tool evaluation questions
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