The Problem
When an advisor leaves, the firm has a standardized set of obligations that nobody owns end-to-end. Form U5 needs to be filed with FINRA inside the regulatory window. BrokerCheck and IAPD need updating. Email and CRM and portfolio system access need to be deprovisioned. Devices need wiping or returning. The custodian portals need access revoked. The final payout has to be calculated against pending fees and disputed items. Garden leave or non-solicit terms need to be communicated to the advisor and enforced. Each client of the departing advisor needs a coordinated communication. The receiving advisor needs a clean handoff memo. The departing advisor''s books and records need to be retained under Rule 204-2 for seven years. And every system the advisor had access to needs an audit pass.
In practice, most of this happens reactively. The CRM access lingers for weeks. Email accounts stay live because nobody pushed the IT ticket through. Client communication is ad-hoc and varies by who picks up the relationship. The handoff memo gets dictated from memory. Garden leave enforcement is loose because nobody is monitoring activity. A departing advisor takes the firm''s top client because the firm never coordinated a serious transition.
This is the mirror image of onboarding. The firm that runs it cleanly protects revenue and reputation. The firm that does not loses clients to its own departing advisors.
Departure Trigger & U5 Filer
Internal SoftwareOpens the structured exit record the day a departure is initiated and files U5 inside the regulatory window
What The Software Does
Opens the exit record the moment departure is initiated by HR or the advisor
Files Form U5 within the regulatory window with proper supervisory disclosures
Pushes the U5 to FINRA and updates BrokerCheck and IAPD
Drafts any required regulatory notifications for the firm
Deprovisioning Orchestrator
Internal SoftwareCoordinates removal of every system access on a defined schedule
What The Software Does
Revokes email, CRM, portfolio, billing, custodian portal, and identity provider access
Returns or wipes devices according to the firm policy
Archives the advisor's mailbox under Rule 204-2 retention
Logs every deprovisioning step with timestamp for the audit trail
Client Transition Coordinator
AI AgentDrafts coordinated client communications and schedules handoff calls with the receiving advisor
What The AI Does
Drafts client communications keyed to each receiving advisor relationship
Generates a handoff memo for the receiving advisor based on the departing advisor's 12 months of activity
Schedules the handoff call with both advisors and the household
Tracks every client acknowledgement and surfaces those that did not respond
Garden Leave Monitor
AI AgentMonitors communications surveillance for non-solicit violations during the garden leave window
What The AI Does
Cross-references the departing advisor's communications against non-solicit clauses
Surfaces outreach to firm clients from the departing advisor's personal channels
Tracks remediation through to close with documented evidence
Provides evidence for any required legal action
Head of Ops + Compliance Sign-Off
Human ReviewHead of operations and compliance review the final payout, communications, and offboarding completion certificate
Review Criteria
Expected Impact
Before:
Offboarding happens reactively, system access lingers, and the firm sometimes finds out an account moved with the advisor before it knew the advisor was gone.
After:
Offboarding runs as a coordinated playbook on day one of the departure. System access closes on schedule. Client transitions are intentional. Garden leave is monitored automatically.
Result:
100 percent access deprovisioning within 24 hours of separation, U5 filed within the regulatory window every time, and zero books-and-records gaps in post-departure archives