--- name: client-onboarding description: "Design and implement end-to-end client onboarding workflows from prospect intake through funded account, covering KYC verification, document collection, e-signature, and custodian submission. Use when the user asks about building a digital onboarding flow, integrating identity verification or CIP checks, reducing NIGO rejection rates, opening complex account types like trusts or entities, connecting to custodian APIs, designing suitability questionnaires, or comparing advisor-assisted vs self-service models. Also trigger when users mention 'new account opening', 'onboarding bottleneck', 'KYC integration', 'beneficial ownership', 'OFAC screening', 'account funding', or 'onboarding automation'." ---

# Client Onboarding

## Core Concepts

### Onboarding Workflow Architecture Client onboarding is an orchestrated, multi-stage process that transforms a prospect into a funded, investable account. The canonical stages are:

1. **Prospect intake** — capture contact information, establish CRM record, assign advisor 2. **Identity verification** — CIP/KYC checks (name, DOB, address, SSN/TIN, government ID) 3. **Suitability data collection** — investment objectives, risk tolerance, time horizon, financial situation 4. **Account type selection** — individual, joint, trust, IRA, entity, or other structure 5. **Document generation** — assemble the required document package based on account type and features 6. **E-signature** — execute new account forms, agreements, and disclosures electronically 7. **Custodian submission** — transmit the completed application to the custodian for account creation 8. **Funding** — ACH, wire, ACAT transfer, or check deposit to fund the new account 9. **Initial investment** — assign the funded account to a model portfolio or execute the initial trade

The two primary flow models are **advisor-assisted** and **self-service (digital-direct)**. In advisor-assisted onboarding, the advisor guides the client through each step, often in a meeting or screen-share, with the onboarding platform pre-populating data from the CRM. In self-service onboarding, the client completes a guided digital workflow independently, with the advisor reviewing and approving the completed application. Most firms support a hybrid model where self-service handles simple account types and advisor-assisted handles complex ones.

The onboarding platform acts as an orchestrator across multiple downstream systems: CRM (client master), KYC/AML vendor (identity verification), custodian (account opening API), document management (storage and retrieval), and portfolio management system (model assignment). The platform must manage state transitions, handle errors at each stage, and provide visibility to both the advisor and compliance.

### Digital Identity Verification Identity verification during onboarding must satisfy CIP requirements under USA PATRIOT Act Section 326 and, for legal entities, the FinCEN CDD Rule (31 CFR 1010.230). The onboarding workflow collects the following minimum identifying information:

- **Individuals:** Full legal name, date of birth, residential address, Social Security Number (or TIN for non-citizens) - **Entities:** Legal name, formation date, principal place of business, EIN/TIN, formation documents

**Verification methods integrated into digital onboarding:**

- **Database verification** — real-time API calls to identity verification vendors (LexisNexis Risk Solutions, Equifax, TransUnion, Alloy) that cross-reference provided data against credit bureau, public records, and government databases. This is the most common method for digital onboarding because it requires no document handling and provides a pass/fail result in seconds. - **Document verification** — the client uploads a photo of a government-issued ID (driver's license, passport), and optionally a selfie for facial comparison. OCR extracts data fields; liveness detection prevents spoofing. Used as a fallback when database verification is inconclusive or as a primary method for non-US persons. - **Knowledge-based authentication (KBA)** — the client answers challenge questions generated from their credit file (e.g., "Which of the following addresses have you lived at?"). KBA is declining in use due to data breach exposure but remains a supplementary method. - **Biometric verification** — fingerprint or facial recognition, typically used in mobile onboarding flows.

**OFAC and sanctions screening** is a mandatory gate before account opening. The onboarding platform must screen all individuals associated with the account (account holders, authorized signers, beneficial owners, trustees) against the OFAC SDN list, FinCEN 314(a) lists, and any firm-specific restricted lists. A match or potential match must halt the onboarding flow and route to compliance for manual review.

**Beneficial ownership collection for entity accounts** requires identification of every individual who directly or indirectly owns 25% or more of the equity interests in the legal entity, plus at least one individual with significant managerial control (the control person). The onboarding workflow must dynamically present beneficial ownership forms when the account type is an entity (LLC, corporation, partnership, certain trusts).

**Enhanced due diligence triggers** that the onboarding system should detect and flag: politically exposed persons (PEPs), connections to high-risk jurisdictions (per FinCEN advisories and FATF guidance), complex multi-layered ownership structures, and negative news screening results. When EDD is triggered, the onboarding flow should pause and escalate to the compliance team before proceeding.

### Suitability and Risk Profiling Onboarding is the primary data collection event for investment suitability. Before any investment recommendation can be made, the firm must gather sufficient information to satisfy FINRA Rule 2111 (suitability) for broker-dealers and Regulation Best Interest for BD recommendations, or the fiduciary duty of care for registered investment advisers.

**Required data elements:** - Investment objectives (capital preservation, income, growth, aggressive growth, speculation) - Time horizon (short-term under 3 years, intermediate 3-10 years, long-term over 10 years) - Risk tolerance (conservative, moderate, aggressive — and the behavioral willingness to endure volatility) - Liquidity needs (anticipated withdrawals, major expenses, emergency reserves) - Annual income and net worth (including liquid net worth) - Investment experience (years of experience, asset classes traded, knowledge level) - Tax status (marginal tax bracket, tax-sensitive vs tax-exempt accounts) - Special circumstances (concentrated stock positions, employer restrictions, ESG preferences)

**Risk questionnaire design** follows two approaches:

- **Psychometric questionnaires** measure the client's emotional and behavioral relationship with risk — willingness to accept losses, reaction to market downturns, comfort with uncertainty. These are better at capturing true risk tolerance but can be subjective. - **Knowledge-based questionnaires** assess the client's understanding of investment concepts and their objective financial capacity to bear risk. These are more defensible from a compliance standpoint but may not capture behavioral tendencies.

Best practice is a combined approach: psychometric questions to assess willingness, financial data to assess capacity, and a mapping algorithm that produces a risk score or category. The risk score then maps to a model portfolio or investment strategy range.

**Regulatory requirements at onboarding:** The suitability profile must be documented before the first investment recommendation. For discretionary accounts, the investment policy statement (IPS) should be established during onboarding. For Reg BI accounts, the Care Obligation requires that any recommendation — including account type — have a reasonable basis given the client's profile.

### Account Type Selection and Configuration The onboarding workflow must guide account type selection based on the client's needs. Account types and their key characteristics:

**Individual and joint accounts:** - Individual taxable — single owner, simplest structure - Joint Tenants with Right of Survivorship (JTWROS) — co-owners; on death, surviving owner inherits automatically - Tenants in Common (TIC) — co-owners; each owns a specified share that passes to their estate - Community Property — available in community property states; assets acquired during marriage are jointly owned

**Retirement accounts:** - Traditional IRA — tax-deductible contributions (subject to income limits), tax-deferred growth, RMDs at age 73 - Roth IRA — after-tax contributions, tax-free growth and qualified withdrawals, no RMDs during owner's lifetime - SEP IRA — employer-funded; contribution limits up to 25% of compensation or the annual dollar limit - SIMPLE IRA — employee salary deferral plus employer match or non-elective contribution - Inherited IRA — beneficiary account; subject to 10-year distribution rule (SECURE Act) for most non-spouse beneficiaries

**Trust accounts:** - Revocable (living) trust — grantor maintains control; assets avoid probate; grantor's SSN typically used as TIN - Irrevocable trust — grantor gives up control; separate tax entity with its own EIN; beneficial ownership rules apply - Testamentary trust — created by will; requires court documentation

**Entity accounts:** - LLC — requires articles of organization, operating agreement, EIN, beneficial ownership certification - Corporation (C-Corp, S-Corp) — requires articles of incorporation, bylaws, corporate resolution, EIN - Partnership (LP, LLP, GP) — requires partnership agreement, EIN, identification of general partner(s)

**Custodial accounts:** - UTMA/UGMA — custodian manages assets for a minor until the age of majority (18 or 21 depending on state)

**Estate accounts:** - Require letters testamentary or letters of administration, death certificate, EIN for the estate

**Account features configured during onboarding:** - Margin eligibility (requires separate margin agreement and additional disclosures) - Options approval level (levels 0-4 depending on custodian; requires options agreement and risk disclosure) - Check writing and debit card access - Tax lot accounting method selection (specific identification, FIFO, average cost) - Beneficiary designation (primary and contingent for retirement and TOD accounts) - Dividend and capital gains reinvestment preferences - Trusted contact person (FINRA Rule 4512)

### Document Collection and Generation Each account type requires a specific document package. The onboarding system should dynamically assemble the required documents based on the account type and features selected.

**Universal documents (all account types):** - New account application form (custodian-specific) - W-9 (US persons) or W-8BEN/W-8BEN-E (non-US persons) - Advisory agreement or brokerage agreement - Form CRS (Client Relationship Summary) - Privacy notice (Reg S-P) - Trusted contact person designation

**Account-type-specific documents:** - Joint accounts: joint account agreement specifying ownership type - Trust accounts: trust certification (or full trust agreement), trustee identification, trust TIN documentation - Entity accounts: formation documents (articles of incorporation/organization, partnership agreement), corporate resolution or operating agreement authorizing the account, beneficial ownership certification form (FinCEN) - IRA accounts: IRA adoption agreement, beneficiary designation form, IRA disclosure statement, rollover/transfer forms (if funding from another retirement account) - Estate accounts: letters testamentary/administration, death certificate, EIN assignment letter - Custodial accounts (UTMA/UGMA): custodial account agreement, minor's SSN

**Feature-specific documents:** - Margin: margin agreement, ma

--- name: client-onboarding description: "Design and implement end-to-end client onboarding workflows from prospect intake through funded account, covering KYC verification, document collection, e-signature, and custodian submission. Use when the user asks about building a digital onboarding flow, integrating identity verification or CIP checks, reducing NIGO rejection rates, opening complex account types like trusts or entities, connecting to custodian APIs, designing suitability questionnaires, or comparing advisor-assisted vs self-service models. Also trigger when users mention 'new account opening', 'onboarding bottleneck', 'KYC integration', 'beneficial ownership', 'OFAC screening', 'account funding', or 'onboarding automation'." ---

# Client Onboarding

## Core Concepts

### Onboarding Workflow Architecture Client onboarding is an orchestrated, multi-stage process that transforms a prospect into a funded, investable account. The canonical stages are:

1. **Prospect intake** — capture contact information, establish CRM record, assign advisor 2. **Identity verification** — CIP/KYC checks (name, DOB, address, SSN/TIN, government ID) 3. **Suitability data collection** — investment objectives, risk tolerance, time horizon, financial situation 4. **Account type selection** — individual, joint, trust, IRA, entity, or other structure 5. **Document generation** — assemble the required document package based on account type and features 6. **E-signature** — execute new account forms, agreements, and disclosures electronically 7. **Custodian submission** — transmit the completed application to the custodian for account creation 8. **Funding** — ACH, wire, ACAT transfer, or check deposit to fund the new account 9. **Initial investment** — assign the funded account to a model portfolio or execute the initial trade

The two primary flow models are **advisor-assisted** and **self-service (digital-direct)**. In advisor-assisted onboarding, the advisor guides the client through each step, often in a meeting or screen-share, with the onboarding platform pre-populating data from the CRM. In self-service onboarding, the client completes a guided digital workflow independently, with the advisor reviewing and approving the completed application. Most firms support a hybrid model where self-service handles simple account types and advisor-assisted handles complex ones.

The onboarding platform acts as an orchestrator across multiple downstream systems: CRM (client master), KYC/AML vendor (identity verification), custodian (account opening API), document management (storage and retrieval), and portfolio management system (model assignment). The platform must manage state transitions, handle errors at each stage, and provide visibility to both the advisor and compliance.

### Digital Identity Verification Identity verification during onboarding must satisfy CIP requirements under USA PATRIOT Act Section 326 and, for legal entities, the FinCEN CDD Rule (31 CFR 1010.230). The onboarding workflow collects the following minimum identifying information:

- **Individuals:** Full legal name, date of birth, residential address, Social Security Number (or TIN for non-citizens) - **Entities:** Legal name, formation date, principal place of business, EIN/TIN, formation documents

**Verification methods integrated into digital onboarding:**

- **Database verification** — real-time API calls to identity verification vendors (LexisNexis Risk Solutions, Equifax, TransUnion, Alloy) that cross-reference provided data against credit bureau, public records, and government databases. This is the most common method for digital onboarding because it requires no document handling and provides a pass/fail result in seconds. - **Document verification** — the client uploads a photo of a government-issued ID (driver's license, passport), and optionally a selfie for facial comparison. OCR extracts data fields; liveness detection prevents spoofing. Used as a fallback when database verification is inconclusive or as a primary method for non-US persons. - **Knowledge-based authentication (KBA)** — the client answers challenge questions generated from their credit file (e.g., "Which of the following addresses have you lived at?"). KBA is declining in use due to data breach exposure but remains a supplementary method. - **Biometric verification** — fingerprint or facial recognition, typically used in mobile onboarding flows.

**OFAC and sanctions screening** is a mandatory gate before account opening. The onboarding platform must screen all individuals associated with the account (account holders, authorized signers, beneficial owners, trustees) against the OFAC SDN list, FinCEN 314(a) lists, and any firm-specific restricted lists. A match or potential match must halt the onboarding flow and route to compliance for manual review.

**Beneficial ownership collection for entity accounts** requires identification of every individual who directly or indirectly owns 25% or more of the equity interests in the legal entity, plus at least one individual with significant managerial control (the control person). The onboarding workflow must dynamically present beneficial ownership forms when the account type is an entity (LLC, corporation, partnership, certain trusts).

**Enhanced due diligence triggers** that the onboarding system should detect and flag: politically exposed persons (PEPs), connections to high-risk jurisdictions (per FinCEN advisories and FATF guidance), complex multi-layered ownership structures, and negative news screening results. When EDD is triggered, the onboarding flow should pause and escalate to the compliance team before proceeding.

### Suitability and Risk Profiling Onboarding is the primary data collection event for investment suitability. Before any investment recommendation can be made, the firm must gather sufficient information to satisfy FINRA Rule 2111 (suitability) for broker-dealers and Regulation Best Interest for BD recommendations, or the fiduciary duty of care for registered investment advisers.

**Required data elements:** - Investment objectives (capital preservation, income, growth, aggressive growth, speculation) - Time horizon (short-term under 3 years, intermediate 3-10 years, long-term over 10 years) - Risk tolerance (conservative, moderate, aggressive — and the behavioral willingness to endure volatility) - Liquidity needs (anticipated withdrawals, major expenses, emergency reserves) - Annual income and net worth (including liquid net worth) - Investment experience (years of experience, asset classes traded, knowledge level) - Tax status (marginal tax bracket, tax-sensitive vs tax-exempt accounts) - Special circumstances (concentrated stock positions, employer restrictions, ESG preferences)

**Risk questionnaire design** follows two approaches:

- **Psychometric questionnaires** measure the client's emotional and behavioral relationship with risk — willingness to accept losses, reaction to market downturns, comfort with uncertainty. These are better at capturing true risk tolerance but can be subjective. - **Knowledge-based questionnaires** assess the client's understanding of investment concepts and their objective financial capacity to bear risk. These are more defensible from a compliance standpoint but may not capture behavioral tendencies.

Best practice is a combined approach: psychometric questions to assess willingness, financial data to assess capacity, and a mapping algorithm that produces a risk score or category. The risk score then maps to a model portfolio or investment strategy range.

**Regulatory requirements at onboarding:** The suitability profile must be documented before the first investment recommendation. For discretionary accounts, the investment policy statement (IPS) should be established during onboarding. For Reg BI accounts, the Care Obligation requires that any recommendation — including account type — have a reasonable basis given the client's profile.

### Account Type Selection and Configuration The onboarding workflow must guide account type selection based on the client's needs. Account types and their key characteristics:

**Individual and joint accounts:** - Individual taxable — single owner, simplest structure - Joint Tenants with Right of Survivorship (JTWROS) — co-owners; on death, surviving owner inherits automatically - Tenants in Common (TIC) — co-owners; each owns a specified share that passes to their estate - Community Property — available in community property states; assets acquired during marriage are jointly owned

**Retirement accounts:** - Traditional IRA — tax-deductible contributions (subject to income limits), tax-deferred growth, RMDs at age 73 - Roth IRA — after-tax contributions, tax-free growth and qualified withdrawals, no RMDs during owner's lifetime - SEP IRA — employer-funded; contribution limits up to 25% of compensation or the annual dollar limit - SIMPLE IRA — employee salary deferral plus employer match or non-elective contribution - Inherited IRA — beneficiary account; subject to 10-year distribution rule (SECURE Act) for most non-spouse beneficiaries

**Trust accounts:** - Revocable (living) trust — grantor maintains control; assets avoid probate; grantor's SSN typically used as TIN - Irrevocable trust — grantor gives up control; separate tax entity with its own EIN; beneficial ownership rules apply - Testamentary trust — created by will; requires court documentation

**Entity accounts:** - LLC — requires articles of organization, operating agreement, EIN, beneficial ownership certification - Corporation (C-Corp, S-Corp) — requires articles of incorporation, bylaws, corporate resolution, EIN - Partnership (LP, LLP, GP) — requires partnership agreement, EIN, identification of general partner(s)

**Custodial accounts:** - UTMA/UGMA — custodian manages assets for a minor until the age of majority (18 or 21 depending on state)

**Estate accounts:** - Require letters testamentary or letters of administration, death certificate, EIN for the estate

**Account features configured during onboarding:** - Margin eligibility (requires separate margin agreement and additional disclosures) - Options approval level (levels 0-4 depending on custodian; requires options agreement and risk disclosure) - Check writing and debit card access - Tax lot accounting method selection (specific identification, FIFO, average cost) - Beneficiary designation (primary and contingent for retirement and TOD accounts) - Dividend and capital gains reinvestment preferences - Trusted contact person (FINRA Rule 4512)

### Document Collection and Generation Each account type requires a specific document package. The onboarding system should dynamically assemble the required documents based on the account type and features selected.

**Universal documents (all account types):** - New account application form (custodian-specific) - W-9 (US persons) or W-8BEN/W-8BEN-E (non-US persons) - Advisory agreement or brokerage agreement - Form CRS (Client Relationship Summary) - Privacy notice (Reg S-P) - Trusted contact person designation

**Account-type-specific documents:** - Joint accounts: joint account agreement specifying ownership type - Trust accounts: trust certification (or full trust agreement), trustee identification, trust TIN documentation - Entity accounts: formation documents (articles of incorporation/organization, partnership agreement), corporate resolution or operating agreement authorizing the account, beneficial ownership certification form (FinCEN) - IRA accounts: IRA adoption agreement, beneficiary designation form, IRA disclosure statement, rollover/transfer forms (if funding from another retirement account) - Estate accounts: letters testamentary/administration, death certificate, EIN assignment letter - Custodial accounts (UTMA/UGMA): custodial account agreement, minor's SSN

**Feature-specific documents:** - Margin: margin agreement, ma

--- name: client-onboarding description: "Design and implement end-to-end client onboarding workflows from prospect intake through funded account, covering KYC verification, document collection, e-signature, and custodian submission. Use when the user asks about building a digital onboarding flow, integrating identity verification or CIP checks, reducing NIGO rejection rates, opening complex account types like trusts or entities, connecting to custodian APIs, designing suitability questionnaires, or comparing advisor-assisted vs self-service models. Also trigger when users mention 'new account opening', 'onboarding bottleneck', 'KYC integration', 'beneficial ownership', 'OFAC screening', 'account funding', or 'onboarding automation'." ---

# Client Onboarding

## Core Concepts

### Onboarding Workflow Architecture Client onboarding is an orchestrated, multi-stage process that transforms a prospect into a funded, investable account. The canonical stages are:

1. **Prospect intake** — capture contact information, establish CRM record, assign advisor 2. **Identity verification** — CIP/KYC checks (name, DOB, address, SSN/TIN, government ID) 3. **Suitability data collection** — investment objectives, risk tolerance, time horizon, financial situation 4. **Account type selection** — individual, joint, trust, IRA, entity, or other structure 5. **Document generation** — assemble the required document package based on account type and features 6. **E-signature** — execute new account forms, agreements, and disclosures electronically 7. **Custodian submission** — transmit the completed application to the custodian for account creation 8. **Funding** — ACH, wire, ACAT transfer, or check deposit to fund the new account 9. **Initial investment** — assign the funded account to a model portfolio or execute the initial trade

The two primary flow models are **advisor-assisted** and **self-service (digital-direct)**. In advisor-assisted onboarding, the advisor guides the client through each step, often in a meeting or screen-share, with the onboarding platform pre-populating data from the CRM. In self-service onboarding, the client completes a guided digital workflow independently, with the advisor reviewing and approving the completed application. Most firms support a hybrid model where self-service handles simple account types and advisor-assisted handles complex ones.

The onboarding platform acts as an orchestrator across multiple downstream systems: CRM (client master), KYC/AML vendor (identity verification), custodian (account opening API), document management (storage and retrieval), and portfolio management system (model assignment). The platform must manage state transitions, handle errors at each stage, and provide visibility to both the advisor and compliance.

### Digital Identity Verification Identity verification during onboarding must satisfy CIP requirements under USA PATRIOT Act Section 326 and, for legal entities, the FinCEN CDD Rule (31 CFR 1010.230). The onboarding workflow collects the following minimum identifying information:

- **Individuals:** Full legal name, date of birth, residential address, Social Security Number (or TIN for non-citizens) - **Entities:** Legal name, formation date, principal place of business, EIN/TIN, formation documents

**Verification methods integrated into digital onboarding:**

- **Database verification** — real-time API calls to identity verification vendors (LexisNexis Risk Solutions, Equifax, TransUnion, Alloy) that cross-reference provided data against credit bureau, public records, and government databases. This is the most common method for digital onboarding because it requires no document handling and provides a pass/fail result in seconds. - **Document verification** — the client uploads a photo of a government-issued ID (driver's license, passport), and optionally a selfie for facial comparison. OCR extracts data fields; liveness detection prevents spoofing. Used as a fallback when database verification is inconclusive or as a primary method for non-US persons. - **Knowledge-based authentication (KBA)** — the client answers challenge questions generated from their credit file (e.g., "Which of the following addresses have you lived at?"). KBA is declining in use due to data breach exposure but remains a supplementary method. - **Biometric verification** — fingerprint or facial recognition, typically used in mobile onboarding flows.

**OFAC and sanctions screening** is a mandatory gate before account opening. The onboarding platform must screen all individuals associated with the account (account holders, authorized signers, beneficial owners, trustees) against the OFAC SDN list, FinCEN 314(a) lists, and any firm-specific restricted lists. A match or potential match must halt the onboarding flow and route to compliance for manual review.

**Beneficial ownership collection for entity accounts** requires identification of every individual who directly or indirectly owns 25% or more of the equity interests in the legal entity, plus at least one individual with significant managerial control (the control person). The onboarding workflow must dynamically present beneficial ownership forms when the account type is an entity (LLC, corporation, partnership, certain trusts).

**Enhanced due diligence triggers** that the onboarding system should detect and flag: politically exposed persons (PEPs), connections to high-risk jurisdictions (per FinCEN advisories and FATF guidance), complex multi-layered ownership structures, and negative news screening results. When EDD is triggered, the onboarding flow should pause and escalate to the compliance team before proceeding.

### Suitability and Risk Profiling Onboarding is the primary data collection event for investment suitability. Before any investment recommendation can be made, the firm must gather sufficient information to satisfy FINRA Rule 2111 (suitability) for broker-dealers and Regulation Best Interest for BD recommendations, or the fiduciary duty of care for registered investment advisers.

**Required data elements:** - Investment objectives (capital preservation, income, growth, aggressive growth, speculation) - Time horizon (short-term under 3 years, intermediate 3-10 years, long-term over 10 years) - Risk tolerance (conservative, moderate, aggressive — and the behavioral willingness to endure volatility) - Liquidity needs (anticipated withdrawals, major expenses, emergency reserves) - Annual income and net worth (including liquid net worth) - Investment experience (years of experience, asset classes traded, knowledge level) - Tax status (marginal tax bracket, tax-sensitive vs tax-exempt accounts) - Special circumstances (concentrated stock positions, employer restrictions, ESG preferences)

**Risk questionnaire design** follows two approaches:

- **Psychometric questionnaires** measure the client's emotional and behavioral relationship with risk — willingness to accept losses, reaction to market downturns, comfort with uncertainty. These are better at capturing true risk tolerance but can be subjective. - **Knowledge-based questionnaires** assess the client's understanding of investment concepts and their objective financial capacity to bear risk. These are more defensible from a compliance standpoint but may not capture behavioral tendencies.

Best practice is a combined approach: psychometric questions to assess willingness, financial data to assess capacity, and a mapping algorithm that produces a risk score or category. The risk score then maps to a model portfolio or investment strategy range.

**Regulatory requirements at onboarding:** The suitability profile must be documented before the first investment recommendation. For discretionary accounts, the investment policy statement (IPS) should be established during onboarding. For Reg BI accounts, the Care Obligation requires that any recommendation — including account type — have a reasonable basis given the client's profile.

### Account Type Selection and Configuration The onboarding workflow must guide account type selection based on the client's needs. Account types and their key characteristics:

**Individual and joint accounts:** - Individual taxable — single owner, simplest structure - Joint Tenants with Right of Survivorship (JTWROS) — co-owners; on death, surviving owner inherits automatically - Tenants in Common (TIC) — co-owners; each owns a specified share that passes to their estate - Community Property — available in community property states; assets acquired during marriage are jointly owned

**Retirement accounts:** - Traditional IRA — tax-deductible contributions (subject to income limits), tax-deferred growth, RMDs at age 73 - Roth IRA — after-tax contributions, tax-free growth and qualified withdrawals, no RMDs during owner's lifetime - SEP IRA — employer-funded; contribution limits up to 25% of compensation or the annual dollar limit - SIMPLE IRA — employee salary deferral plus employer match or non-elective contribution - Inherited IRA — beneficiary account; subject to 10-year distribution rule (SECURE Act) for most non-spouse beneficiaries

**Trust accounts:** - Revocable (living) trust — grantor maintains control; assets avoid probate; grantor's SSN typically used as TIN - Irrevocable trust — grantor gives up control; separate tax entity with its own EIN; beneficial ownership rules apply - Testamentary trust — created by will; requires court documentation

**Entity accounts:** - LLC — requires articles of organization, operating agreement, EIN, beneficial ownership certification - Corporation (C-Corp, S-Corp) — requires articles of incorporation, bylaws, corporate resolution, EIN - Partnership (LP, LLP, GP) — requires partnership agreement, EIN, identification of general partner(s)

**Custodial accounts:** - UTMA/UGMA — custodian manages assets for a minor until the age of majority (18 or 21 depending on state)

**Estate accounts:** - Require letters testamentary or letters of administration, death certificate, EIN for the estate

**Account features configured during onboarding:** - Margin eligibility (requires separate margin agreement and additional disclosures) - Options approval level (levels 0-4 depending on custodian; requires options agreement and risk disclosure) - Check writing and debit card access - Tax lot accounting method selection (specific identification, FIFO, average cost) - Beneficiary designation (primary and contingent for retirement and TOD accounts) - Dividend and capital gains reinvestment preferences - Trusted contact person (FINRA Rule 4512)

### Document Collection and Generation Each account type requires a specific document package. The onboarding system should dynamically assemble the required documents based on the account type and features selected.

**Universal documents (all account types):** - New account application form (custodian-specific) - W-9 (US persons) or W-8BEN/W-8BEN-E (non-US persons) - Advisory agreement or brokerage agreement - Form CRS (Client Relationship Summary) - Privacy notice (Reg S-P) - Trusted contact person designation

**Account-type-specific documents:** - Joint accounts: joint account agreement specifying ownership type - Trust accounts: trust certification (or full trust agreement), trustee identification, trust TIN documentation - Entity accounts: formation documents (articles of incorporation/organization, partnership agreement), corporate resolution or operating agreement authorizing the account, beneficial ownership certification form (FinCEN) - IRA accounts: IRA adoption agreement, beneficiary designation form, IRA disclosure statement, rollover/transfer forms (if funding from another retirement account) - Estate accounts: letters testamentary/administration, death certificate, EIN assignment letter - Custodial accounts (UTMA/UGMA): custodial account agreement, minor's SSN

**Feature-specific documents:** - Margin: margin agreement, ma

--- name: client-onboarding description: "Design and implement end-to-end client onboarding workflows from prospect intake through funded account, covering KYC verification, document collection, e-signature, and custodian submission. Use when the user asks about building a digital onboarding flow, integrating identity verification or CIP checks, reducing NIGO rejection rates, opening complex account types like trusts or entities, connecting to custodian APIs, designing suitability questionnaires, or comparing advisor-assisted vs self-service models. Also trigger when users mention 'new account opening', 'onboarding bottleneck', 'KYC integration', 'beneficial ownership', 'OFAC screening', 'account funding', or 'onboarding automation'." ---

# Client Onboarding

## Core Concepts

### Onboarding Workflow Architecture Client onboarding is an orchestrated, multi-stage process that transforms a prospect into a funded, investable account. The canonical stages are:

1. **Prospect intake** — capture contact information, establish CRM record, assign advisor 2. **Identity verification** — CIP/KYC checks (name, DOB, address, SSN/TIN, government ID) 3. **Suitability data collection** — investment objectives, risk tolerance, time horizon, financial situation 4. **Account type selection** — individual, joint, trust, IRA, entity, or other structure 5. **Document generation** — assemble the required document package based on account type and features 6. **E-signature** — execute new account forms, agreements, and disclosures electronically 7. **Custodian submission** — transmit the completed application to the custodian for account creation 8. **Funding** — ACH, wire, ACAT transfer, or check deposit to fund the new account 9. **Initial investment** — assign the funded account to a model portfolio or execute the initial trade

The two primary flow models are **advisor-assisted** and **self-service (digital-direct)**. In advisor-assisted onboarding, the advisor guides the client through each step, often in a meeting or screen-share, with the onboarding platform pre-populating data from the CRM. In self-service onboarding, the client completes a guided digital workflow independently, with the advisor reviewing and approving the completed application. Most firms support a hybrid model where self-service handles simple account types and advisor-assisted handles complex ones.

The onboarding platform acts as an orchestrator across multiple downstream systems: CRM (client master), KYC/AML vendor (identity verification), custodian (account opening API), document management (storage and retrieval), and portfolio management system (model assignment). The platform must manage state transitions, handle errors at each stage, and provide visibility to both the advisor and compliance.

### Digital Identity Verification Identity verification during onboarding must satisfy CIP requirements under USA PATRIOT Act Section 326 and, for legal entities, the FinCEN CDD Rule (31 CFR 1010.230). The onboarding workflow collects the following minimum identifying information:

- **Individuals:** Full legal name, date of birth, residential address, Social Security Number (or TIN for non-citizens) - **Entities:** Legal name, formation date, principal place of business, EIN/TIN, formation documents

**Verification methods integrated into digital onboarding:**

- **Database verification** — real-time API calls to identity verification vendors (LexisNexis Risk Solutions, Equifax, TransUnion, Alloy) that cross-reference provided data against credit bureau, public records, and government databases. This is the most common method for digital onboarding because it requires no document handling and provides a pass/fail result in seconds. - **Document verification** — the client uploads a photo of a government-issued ID (driver's license, passport), and optionally a selfie for facial comparison. OCR extracts data fields; liveness detection prevents spoofing. Used as a fallback when database verification is inconclusive or as a primary method for non-US persons. - **Knowledge-based authentication (KBA)** — the client answers challenge questions generated from their credit file (e.g., "Which of the following addresses have you lived at?"). KBA is declining in use due to data breach exposure but remains a supplementary method. - **Biometric verification** — fingerprint or facial recognition, typically used in mobile onboarding flows.

**OFAC and sanctions screening** is a mandatory gate before account opening. The onboarding platform must screen all individuals associated with the account (account holders, authorized signers, beneficial owners, trustees) against the OFAC SDN list, FinCEN 314(a) lists, and any firm-specific restricted lists. A match or potential match must halt the onboarding flow and route to compliance for manual review.

**Beneficial ownership collection for entity accounts** requires identification of every individual who directly or indirectly owns 25% or more of the equity interests in the legal entity, plus at least one individual with significant managerial control (the control person). The onboarding workflow must dynamically present beneficial ownership forms when the account type is an entity (LLC, corporation, partnership, certain trusts).

**Enhanced due diligence triggers** that the onboarding system should detect and flag: politically exposed persons (PEPs), connections to high-risk jurisdictions (per FinCEN advisories and FATF guidance), complex multi-layered ownership structures, and negative news screening results. When EDD is triggered, the onboarding flow should pause and escalate to the compliance team before proceeding.

### Suitability and Risk Profiling Onboarding is the primary data collection event for investment suitability. Before any investment recommendation can be made, the firm must gather sufficient information to satisfy FINRA Rule 2111 (suitability) for broker-dealers and Regulation Best Interest for BD recommendations, or the fiduciary duty of care for registered investment advisers.

**Required data elements:** - Investment objectives (capital preservation, income, growth, aggressive growth, speculation) - Time horizon (short-term under 3 years, intermediate 3-10 years, long-term over 10 years) - Risk tolerance (conservative, moderate, aggressive — and the behavioral willingness to endure volatility) - Liquidity needs (anticipated withdrawals, major expenses, emergency reserves) - Annual income and net worth (including liquid net worth) - Investment experience (years of experience, asset classes traded, knowledge level) - Tax status (marginal tax bracket, tax-sensitive vs tax-exempt accounts) - Special circumstances (concentrated stock positions, employer restrictions, ESG preferences)

**Risk questionnaire design** follows two approaches:

- **Psychometric questionnaires** measure the client's emotional and behavioral relationship with risk — willingness to accept losses, reaction to market downturns, comfort with uncertainty. These are better at capturing true risk tolerance but can be subjective. - **Knowledge-based questionnaires** assess the client's understanding of investment concepts and their objective financial capacity to bear risk. These are more defensible from a compliance standpoint but may not capture behavioral tendencies.

Best practice is a combined approach: psychometric questions to assess willingness, financial data to assess capacity, and a mapping algorithm that produces a risk score or category. The risk score then maps to a model portfolio or investment strategy range.

**Regulatory requirements at onboarding:** The suitability profile must be documented before the first investment recommendation. For discretionary accounts, the investment policy statement (IPS) should be established during onboarding. For Reg BI accounts, the Care Obligation requires that any recommendation — including account type — have a reasonable basis given the client's profile.

### Account Type Selection and Configuration The onboarding workflow must guide account type selection based on the client's needs. Account types and their key characteristics:

**Individual and joint accounts:** - Individual taxable — single owner, simplest structure - Joint Tenants with Right of Survivorship (JTWROS) — co-owners; on death, surviving owner inherits automatically - Tenants in Common (TIC) — co-owners; each owns a specified share that passes to their estate - Community Property — available in community property states; assets acquired during marriage are jointly owned

**Retirement accounts:** - Traditional IRA — tax-deductible contributions (subject to income limits), tax-deferred growth, RMDs at age 73 - Roth IRA — after-tax contributions, tax-free growth and qualified withdrawals, no RMDs during owner's lifetime - SEP IRA — employer-funded; contribution limits up to 25% of compensation or the annual dollar limit - SIMPLE IRA — employee salary deferral plus employer match or non-elective contribution - Inherited IRA — beneficiary account; subject to 10-year distribution rule (SECURE Act) for most non-spouse beneficiaries

**Trust accounts:** - Revocable (living) trust — grantor maintains control; assets avoid probate; grantor's SSN typically used as TIN - Irrevocable trust — grantor gives up control; separate tax entity with its own EIN; beneficial ownership rules apply - Testamentary trust — created by will; requires court documentation

**Entity accounts:** - LLC — requires articles of organization, operating agreement, EIN, beneficial ownership certification - Corporation (C-Corp, S-Corp) — requires articles of incorporation, bylaws, corporate resolution, EIN - Partnership (LP, LLP, GP) — requires partnership agreement, EIN, identification of general partner(s)

**Custodial accounts:** - UTMA/UGMA — custodian manages assets for a minor until the age of majority (18 or 21 depending on state)

**Estate accounts:** - Require letters testamentary or letters of administration, death certificate, EIN for the estate

**Account features configured during onboarding:** - Margin eligibility (requires separate margin agreement and additional disclosures) - Options approval level (levels 0-4 depending on custodian; requires options agreement and risk disclosure) - Check writing and debit card access - Tax lot accounting method selection (specific identification, FIFO, average cost) - Beneficiary designation (primary and contingent for retirement and TOD accounts) - Dividend and capital gains reinvestment preferences - Trusted contact person (FINRA Rule 4512)

### Document Collection and Generation Each account type requires a specific document package. The onboarding system should dynamically assemble the required documents based on the account type and features selected.

**Universal documents (all account types):** - New account application form (custodian-specific) - W-9 (US persons) or W-8BEN/W-8BEN-E (non-US persons) - Advisory agreement or brokerage agreement - Form CRS (Client Relationship Summary) - Privacy notice (Reg S-P) - Trusted contact person designation

**Account-type-specific documents:** - Joint accounts: joint account agreement specifying ownership type - Trust accounts: trust certification (or full trust agreement), trustee identification, trust TIN documentation - Entity accounts: formation documents (articles of incorporation/organization, partnership agreement), corporate resolution or operating agreement authorizing the account, beneficial ownership certification form (FinCEN) - IRA accounts: IRA adoption agreement, beneficiary designation form, IRA disclosure statement, rollover/transfer forms (if funding from another retirement account) - Estate accounts: letters testamentary/administration, death certificate, EIN assignment letter - Custodial accounts (UTMA/UGMA): custodial account agreement, minor's SSN

**Feature-specific documents:** - Margin: margin agreement, ma