Chapter 3 - The Advice Process and Documentation
Client File Management
Effective client file management is essential to demonstrating professionalism, regulatory adherence, and a commitment to acting in clients’ best interests.
Core Principles of Client File Management
Client file management is underpinned by the following principles:
Accuracy and completeness of records
Protection of client privacy and confidentiality
Clear evidence of advice, decisions, and client consent
Secure storage and controlled access
Retention of records in accordance with legal and licensee requirements
Every client file must be capable of being reviewed by a third party (e.g. auditor, regulator, or Responsible Manager) and clearly demonstrate how and why advice was provided.
What Must Be Included in a Client File
Each client file must be complete, accurate, and up to date. At a minimum, it must contain:
All advice documents provided to the client (final versions only)
Supporting documentation used to formulate advice
Signed client documents evidencing receipt and acceptance
Disclosure documents provided (including versions and dates)
Comprehensive file notes of all meetings, calls, and interactions
Correspondence with the client, third parties, product providers, or the licensee
Client files must clearly support:
Best interest duty compliance
Advice rationale and recommendations
Client decision-making and instructions
Complaint handling and regulatory enquiries
Legal, statutory, and stakeholder obligation
Client Relationship Management (CRM) System Requirements
All client files must be stored and maintained within the adviser’s approved Client Relationship Management (CRM) system.
The CRM system is the licensee’s primary record-keeping platform and represents the official and authoritative client file. Advisers must ensure that all client records are uploaded to, and managed within, the CRM and not stored solely in alternative systems or personal devices.
Advisers are required to:
Store all client documentation within the CRM, including:
Fact Finds and client information records
Advice documents (final versions only)
Signed client authorities, consents, and agreements
Disclosure documents and acknowledgements
Supporting documentation and correspondence
Comprehensive file notes of all client interactions
Ensure that the CRM record is:
Complete, accurate, and up to date at all times
Sufficient to demonstrate the basis of advice and decision-making
Capable of being independently reviewed by the Responsible Manager, auditors, or regulators
Upload documents promptly following client interactions or receipt of information, rather than retaining records locally for later transfer.
Monitoring and Supervision Oversight
The CRM is the system relied upon by Insight Investment Partners to:
Monitor adviser compliance and file completeness;
Conduct file reviews and audits;
Respond to client complaints, regulatory requests, and legal proceedings; and
Demonstrate compliance with best interest duty, record-keeping, and privacy obligations.
Failure to maintain complete and accurate client files within the CRM may result in compliance findings, remediation requirements, or disciplinary action.
Practical Compliance Tips for Advisers
Assume every file may be audited.
Write file notes as if they will be read years later by someone unfamiliar with the client
Upload documents promptly and consistently
Never rely on memory—document everything
When in doubt, document the rationale and seek guidance
Summary
Effective client file management is a core professional and regulatory obligation. Properly maintained client files protect clients, advisers, and the licensee, and are fundamental to demonstrating compliance, professionalism, and trustworthiness.
All client files must be stored and maintained within the adviser’s approved Client Relationship Management (CRM) system.
Advisers are expected to embed these practices into their daily workflows and to seek guidance from Compliance if uncertainty arises.