RIA Client Onboarding KYC Data Checklist
Onboarding friction is where high-LTV prospects silently exit. Most onboarding workflows are designed for the modal client (W-2 wages, US-citizen, single state of residence, individual account) and break in interesting ways for the long-tail prospect — H-1B holders, ITIN filers, recent immigrants, dual residents, entity-account beneficial-ownership cases. This checklist covers the structured fields and identity-verification documents needed to handle the full prospect spectrum, mapped to the regulatory requirements they satisfy.
Identity verification (CIP / FINRA Rule 2090)
- Legal name and DOB
Full legal name as it appears on government-issued ID, plus date of birth. Capture maiden name and prior names if relevant — important for cross-references against credit and account history.
demographics.legal_name, demographics.date_of_birth, demographics.prior_names[] - SSN or ITIN
Tax-identification number with type flag. ITIN-filer prospects need an alternative-documentation pathway; do not reject these prospects.
demographics.tax_id, demographics.tax_id_type - Government-issued photo ID
Driver license, passport, or permanent-resident card. Capture issue date and expiration; expired ID is a CIP failure.
kyc.identity_verification.id_type, .id_number, .id_expiration - Residential address
Current residential address with proof-of-address documentation (recent utility bill, bank statement). PO box alone is insufficient.
demographics.residential_address, kyc.identity_verification.proof_of_address
Citizenship and visa status
- Citizenship and visa status
US citizen, permanent resident, visa-holder (with visa type), or other. Drives FBAR / FATCA filing analysis and tax-treaty applicability.
demographics.citizenship_status, demographics.visa_status - Country of origin
Country-of-origin field for non-citizens. Affects treaty-benefit eligibility and source-country tax treatment.
demographics.country_of_origin - Dual citizenship
Boolean flag for dual citizens, with second-country identification. Affects estate planning and may affect FATCA reporting.
demographics.dual_citizen, demographics.second_country
Source of funds and source of wealth
- Source of funds (account opening)
Origin of the funds being deposited at account opening: salary savings, inheritance, business sale, gift, prior account transfer. Required for AML and CIP.
kyc.source_of_funds - Source of wealth (lifetime)
Narrative or structured description of how the client built their wealth: employment, business ownership, inheritance, investment growth, professional services. More important for HNW clients.
kyc.source_of_wealth - Politically Exposed Person (PEP) status
Per FinCEN guidance, screening for PEP status (foreign government officials, family members, close associates). PEP status triggers enhanced due diligence.
kyc.pep_status, kyc.pep_screening_date
Financial profile and risk tolerance
- Income verification
Income with source-type breakdown (W-2 wages, 1099 contractor, K-1 distribution, royalty, business draw, investment, other). Drives suitability and appropriate-product analysis.
income.primary_source_type, income.documented_annual - Net worth verification
Liquid net worth and total net worth with realistic distributional bucketing. Drives accreditation-test eligibility analysis.
assets.liquid_net_worth, assets.total_net_worth - Investment objectives
Structured objectives ranked by priority. Multiple objectives allowed; priority must be explicit and documented.
goals.primary_financial_goals[] - Risk tolerance
Numerical or categorical risk tolerance from completed questionnaire. Document the questionnaire date — annual reassessment is required for FINRA-regulated accounts.
risk_profile.tolerance_score, risk_profile.questionnaire_date
Account-type specific (entity / trust / custodial)
- Entity beneficial ownership
For LLC, partnership, trust, or corporate accounts, beneficial-ownership documentation per FinCEN's CDD rule. Required for entities with multiple owners or layered structures.
kyc.entity_owned, kyc.beneficial_owners[] - Trust documentation
For trust accounts, the trust formation document, grantor identification, trustee identification, and beneficiary structure. Distinguish revocable from irrevocable.
kyc.trust_structure, kyc.trustees[], kyc.beneficiaries[] - Custodial / UTMA-UGMA structures
For custodial accounts, the custodian (parent/guardian) identification, the minor's information, the state-specific age-of-majority, and the planned transition timeline.
kyc.custodian, kyc.minor_info, kyc.age_of_majority
Goals and planning data
- Goal-priority ranking
Structured priority ranking across the canonical goal taxonomy (retirement, education, home purchase, business sale, charitable, transition). Drives initial-recommendation logic.
goals.primary_financial_goals[].priority - Time horizons per goal
Time horizon per goal in years. Multi-goal time horizons drive asset allocation recommendations.
goals.primary_financial_goals[].time_horizon_years - Existing financial relationships
Prior advisor relationships, existing accounts at other custodians, life insurance policies. Required for conflict-of-interest analysis and consolidated planning.
demographics.existing_relationships[]
Key takeaways
- ITIN-filer and visa-holder prospects need an alternative-documentation pathway — rejecting them is a competitive miss, not a compliance requirement.
- Source of funds (at account opening) and source of wealth (lifetime) are different fields — both are required for AML and the distinction matters for HNW clients.
- Entity / trust / custodial accounts have additional KYC requirements beyond individual accounts; the workflow must support these as first-class paths, not exception handling.
- Goal-priority ranking and time-horizon-per-goal are what differentiate a useful initial recommendation from a generic one — capture these structurally at intake.