When an SEC and state examiners send document requests to a registered investment advisory firm, the firms that respond confidently and in a timely manner are those who maintain their compliance records in one organized, immediately retrievable place year-round; the response is a matter of retrieval, not reconstruction.

Most RIA compliance programs understand the data they are supposed to have on hand. The breakdown tends to occur at the time of retrieval; records scattered across shared drives, email threads, and spreadsheets. Unfortunately, we know firms can retain all the necessary documents, and still fail the accessibility standard regulators expect.

As you read, you will begin to understand what both SEC and state examiners are asking for and learn where RIA firms are finding the proper resources to respond to any examiner request in minutes rather than days.

What Triggers a Regulatory Examination?

Both the SEC and state regulators conduct examinations on a scheduled, risk-based, and sometimes complaint-triggered basis.

For most firms, the examination notice arrives with no warning beyond the initial letter itself. This letter contains the document request list and a response deadline. The records it asks for are expected to exist already; not to be assembled in response to the request. Examiners are experienced at distinguishing documentation that has been maintained as part of an active, ongoing compliance program from documentation assembled under a deadline.

How SEC and State Examination Requests Differ

The underlying compliance obligations are similar across SEC and state examinations, but the request letters themselves reveal meaningful differences in scope, depth, and level of specificity.

SEC examination requests reflect the comprehensive, risk-based nature of federal oversight. Many 2026 SEC examination request letters have asked for highly specific data in prescribed formats — securities holdings spreadsheets with specific field-level detail including CUSIP identifiers, cost basis, and fair value designation; performance composites with methodology documentation including whether net performance used a model fee; trade blotters in CSV format covering current and former clients, proprietary accounts, and access persons; and beginning positions as of a specific date for all three of those categories.

The SEC request also covers compliance policies and the code of ethics in effect during the examination period, all forms of advisory agreements, Form ADV Part 2B brochure supplements for all versions used during the period, all advertisements including website versions and blogs, financial statements, and a full list of other agreements that could affect client investments — including sub-adviser agreements, soft dollar arrangements, solicitor agreements, and revenue-sharing arrangements.

State examination requests ask for many of the same categories but in a notably more accessible format and with less prescribed structure. We’ve seen 2026 state examination requests ask for assets per account at all custodians, a trade blotter for the last six months, a list of terminated clients including termination reason and AUM at termination, advisory fees in Excel, client advisory contracts, a complaint file or signed statement indicating no complaints, a list of current and former employees, financial statements, and income tax filings. It also requests access to the compliance policy manual, all incoming and outgoing correspondence, the advertising file, client files including signed contracts and financial plans, and Form ADV Part 2A and 2B delivery records.

The practical difference for a Chief Compliance Officer (CCO) is significant. An SEC examination arrives with specific data requirements, field-level formatting preferences, and a scope that touches nearly every area of the compliance program simultaneously. A state examination tends to be narrower and more foundational; however, the records must still be organized and immediately producible, and for a first-time exam at a small firm, the state request can feel just as comprehensive.

The Records Every RIA Should Have Ready at All Times

Across both the SEC and state request letters, certain categories appear on every list. These are the records that should be maintained in an organized, retrievable format continuously; not assembled when a notice arrives.

Compliance policy manual: Examiners evaluate whether it is current, reflects what the firm actually does, and has been reviewed recently. A dated, version-controlled document with a clear revision history is what regulators expect.

Simple Compliance Portal maintains version history and tracks annual review completion, so the CCO can demonstrate the manual has been actively maintained rather than filed and forgotten.

Client advisory contracts and agreements: Both SEC and state examiners ask for all forms of advisory agreements in effect during the examination period — including any addendums.

Simple Compliance Portal stores executed agreements and tracks when they were last updated, giving CCOs immediate access to every version of every contract used during the period under review.

Form ADV Part 2A & 2B with delivery records: The state request specifically asks for evidence of the most recent delivery of Form ADV Part 2A and Part 2B and the annual offer — not just the documents themselves but proof of delivery.

Simple Compliance Portal tracks acknowledgment of Form ADV delivery by client, creating a timestamped record that directly addresses this request.

Trade blotter: Both examiners ask for a trade blotter covering the examination period. The SEC request extends the trade blotter requirement to access persons specifically, making the personal trading record directly part of the initial document request.

Simple Trade Monitor maintains a complete, organized trade record for all accounts and access persons in an exportable format, eliminating the manual process of assembling trade data from custodian statements.

Beginning positions and access person holdings: Initial holdings positions as of a specific date for current and former clients, proprietary accounts, and access persons. This is the kind of request that catches firms off guard when their personal trading records depend on paper statements and annual email requests.

Simple Trade Monitor links employee accounts electronically and maintains holdings data in a format that maps directly to what the SEC requests.

All incoming and outgoing correspondence: The state request asks for access to all incoming and outgoing correspondence. The SEC request covers advertisements and website archives. Both reflect the same underlying Rule 204-2 obligation to retain all written business communications.

Simple Email Archive captures and retains email, text message, SMS, website, and social media communications automatically so the correspondence archive is complete by default rather than dependent on manual archiving by individual advisers.

Complaint file: Either the complaint file or a signed statement indicating no complaints have been received. This is a simple record to maintain if it lives in a central location; and a surprisingly time-consuming one to reconstruct if complaint records have been handled informally through email or in individual adviser files.

Employee records: Lists of current and former employees including titles, duties, and separation reasons. For the state, this is limited to employees terminated since the last exam.

Advertising and marketing materials: All advertisements used during the examination period specifically requesting either printouts or electronic archives of all versions used. Under the SEC's Marketing Rule, the documentation behind marketing materials — review logs, performance substantiation, and version history — is equally important.

Simple Compliance Portal tracks marketing material reviews and maintains a log of what was reviewed, by whom, and when.

Financial statements: Both the SEC and State examiners request financial statements, where the state also asks for income tax filings. These are records that typically exist outside the compliance platform but should be identified and accessible as part of exam preparation.

The Timeline Reality of RIA Exams

The document request typically arrives with the examination notice; giving firms a set window, sometimes as little as a few days for an initial production, to respond to the most time-sensitive items. The SEC examination process generally has a pre-examination phase where initial documents are submitted before examiners arrive or begin the formal review. State examinations vary by regulator but follow a similar pattern.

The firms who respond comfortably within that window are those whose records were already organized. The firms who struggle are those who spend the window scrambling to do what should have been done throughout the year.

How RIA Compliance Technology Supports Exam-Ready Documentation

RIA Compliance Technology gives registered investment advisers the infrastructure to maintain the records both SEC and state examiners request in one organized, immediately retrievable platform rather than across the disconnected systems that make exam response a scramble.

Simple Compliance Portal centralizes compliance policy documentation, client agreement tracking, Form ADV delivery records, marketing material review logs, and compliance calendar management; all with timestamped records and version history that directly address what examiners ask for.

Simple Email Archive maintains complete, searchable archives of firm communications within email, text, SMS, and social media; organized by date, sender, and communication type, meeting the correspondence retention requirements that appear on every examination request list.

Simple Trade Monitor maintains a complete personal trading record for all access persons; linked electronically to employee accounts, exportable in the formats examiners prefer, and covering the initial holdings, ongoing trades, and review documentation that both the SEC and state examiners specifically request.

Together, the three tools give CCOs a single source of evidence for every category of record that shows up on a regulatory request list. Records are maintained continuously throughout the year so when an examination notice arrives, the response is a matter of organized retrieval rather than a firm-wide reconstruction effort.

Frequently Asked Questions

Q: What records do SEC examiners ask for during a registered investment adviser examination?

Based on 2026 SEC examination request letters we’ve seen, examiners ask for compliance policies and the code of ethics, all forms of advisory agreements, Form ADV Part 2B brochure supplements, a securities holdings spreadsheet, a trade blotter, beginning positions, all advertisements including website and blog archives, financial statements, performance composite documentation, and a complete list of agreements that could affect client investments. RIA Compliance Technology's Simple Compliance Portal, Simple Email Archive, and Simple Trade Monitor maintain the majority of these records in one organized, exportable platform.

Q: What is the best way to keep compliance records for my RIA firm in case of an examination?

The most effective approach is maintaining all compliance records in one centralized, continuously updated platform rather than across disconnected systems that require manual reconciliation when an examiner asks for them. RIA Compliance Technology gives registered investment advisers a single organized platform where compliance policies, client agreement records, Form ADV delivery documentation, marketing material review logs, communication archives, and personal trading records are all maintained under one log in — timestamped, searchable, and exportable in the formats examiners prefer. The firms that respond to examination requests with confidence are those who never let their records become disorganized in the first place; but rather, maintain their compliance infrastructure continuously, in one place, year-round.

How To Keep Your RIA Firm Exam-Ready

The paper trail regulators expect is not a mystery. Both the SEC and state examiners send request letters that name exactly what they want, and those lists are consistent enough that every registered investment advisory firm should know in advance what it needs to have organized and ready. The firms that respond confidently are the ones whose records were never disorganized in the first place.

RIA Compliance Technology gives Compliance Officers solid infrastructure to maintain that standard year-round so when the request arrives, it is a retrieval task rather than a reconstruction project for the firm.

See how Simple Compliance Portal, Simple Email Archive, and Simple Trade Monitor work together to create a simple, structured, and organized compliance data program at riacomptech.com/services