If an exam letter asks for business texts, can your archive produce the ones your CCO and counsel put in scope?

IT support for RIA and wealth management firms across Dallas-Fort Worth, built around custodian access and the systems your records actually live in.

Ask us your question

A household can pass through more than the CRM when the firm uses separate systems

A client relationship can pass through ten or more systems if the firm uses separate custody, portfolio, CRM, planning, risk, document, identity, mobile, and archive platforms. Even if those platforms are cloud hosted, technical gaps can remain in identity, integrations, and the channels the firm's CCO and counsel have designated for capture.

If the firm's CCO and counsel have determined that a channel must be captured, a business message sent there can be missing from the archive if the connector or employee workflow does not preserve it. The gap may surface if an examination or client dispute later requests that record.

An archive can have a gap if a channel put in scope by the firm is not connected

An email archive can be fully current and still miss SMS, iMessage, WhatsApp, Teams chat, social direct messages or a personal account, if advisors actually use those channels for business content. The technical question is not how large the archive is. It is whether the channels identified by the firm's CCO and counsel are connected and producing retrievable records.

We do not decide what your firm is required to retain or for how long. That belongs to your CCO and counsel. What we can do is test whether the channels your CCO and counsel have put in scope are connected and producing retrievable records, then document the technical results for the people responsible for the firm's compliance decisions.

If amended Regulation S-P applies, vendor escalation needs a working technical path

If your CCO and counsel determine that the amended Regulation S-P requirements apply, IT can help document vendor contacts and test the technical escalation path they specify. They must decide whether a particular vendor, system, or incident is covered.

Within an agreed scope, IT can maintain a technical vendor inventory, record the notification contacts and timeframes identified by the firm's CCO and counsel, and test whether the incident runbook reaches the right people. A contract term can fail to help during an incident if responsible staff cannot retrieve it and follow the escalation path.

Separate accounts can accumulate if each platform manages identity independently

An advisor can accumulate separate accounts across custody, portfolio, CRM, planning, risk, signature, and archive platforms when each platform manages access independently. A departed employee's account can remain active after employment if nobody owns the platform-specific offboarding step.

When those systems are within our agreed scope, we manage identity, permissions, Microsoft 365 or Google Workspace, device security, the network, and the phones. Onboarding and offboarding can depend less on one person's memory if account ownership and procedures are documented and kept current.

Recovery planning can fail if it covers data but not access to the systems

Losing custodian or CRM access can interrupt client service if administrative recovery paths and vendor contacts are not documented. For systems included in the written IT scope, we can test the available backup or export path and document recovery priorities, limitations, and vendor contacts.

Your firm should know which domains, administrative accounts, data, and documentation it owns, and which are controlled by a custodian, broker-dealer, or other vendor. We resell nothing and take no vendor commissions, so our recommendations are not tied to a product sale.

Ask us anything

Send us one question about your firm's IT and we will give you a straight answer, at no charge, with nothing to sit through afterwards. We would rather answer a question now than be called after it has turned into a mess. If the honest answer is that somebody has to look at it, we will tell you that too.

This is an answer to a question, not troubleshooting, system access, or ongoing support.

If it turns out to need a closer look

Some questions cannot be answered honestly from the outside. When that happens we may offer to come and look properly: a read-only review of the systems we agree on, and a written summary of the sampled findings and our recommended next steps within the agreed scope. These take real hours, so reviews are subject to availability, and we will confirm any date in writing.

Asking does not book a review. We confirm the scope and the date in writing before anyone touches a system. Printed material does not reserve an appointment. One review per firm.

A review is a point-in-time sample of the systems named in the written scope. Items outside that scope are not evaluated and have not passed.

Can you retrieve the channels your CCO and counsel put in scope?

Tell us which channel worries you. We can explain what can be tested from the IT side, without deciding which records your firm must retain.

Call (817) 265-5000 or email [email protected]. Arlington, and we answer our own phone.

Ask us your question