FICTITIOUS — FORGE DEMO ONLY · SPECIMEN
Of 12 items requested, 4 are holes — nothing responsive on hand today — 4 are partial, and 4 are covered.
A plan, not a production. This points at where responsive records live right now and names what we could not produce today — it copies nothing, moves nothing, and sends nothing. A hole means nothing responsive was found in the office, not that the firm is deficient. Ellen verifies what's truly responsive and produces.
Nothing responsive found in the office. No trade blotter or transaction record of client trades placed or directed sits on any desk. The account statements on Dana's desk (e.g. this statement) are holdings/value records — what an account held, not the trades that were placed — so they don't answer this item.
Why it matters: the blotter is usually an early, expected production — examiners test trading practices, best execution, and allocation from it. With no transaction record we can't evidence how or when client trades were placed or directed.
Nothing responsive found in the office. No written policies-and-procedures manual is on the desks, and no memo documenting the most recent annual review of its adequacy. (The Code of Ethics policy memo is one policy — not the full manual, and not the annual review.)
Why it matters: the manual plus a documented annual review is the backbone of an adviser exam and among the first items an examiner opens; its absence is hard to remediate after the letter arrives.
Nothing responsive found in the office. No marketing or advertising material is filed on any desk. The current ADV brochure refers to a firm website, but the site content itself is not in the office.
Why it matters: under the Marketing Rule, examiners review what was actually disseminated; with nothing on file we can't show what claims went out or substantiate them.
Nothing responsive found in the office. No business continuity plan is on file, and there is no client complaint log — nor a formal record stating "none" for the period.
Why it matters: the BCP is a required record, and the complaint log must be produced or affirmatively stated as none. A silent absence reads to an examiner as a missing required record, not as "we had no complaints."
Have: current Part 2A firm brochure — 2026-03-27-form-adv-part-2a-brochure.md (also .html, .pdf).
Missing: Form ADV Part 1; the Part 2B brochure supplement(s); and all prior versions in effect during the review period. (The amendment planning worksheet is a plan, not a filed version.)
Have: current Form CRS — 2026-03-27-form-crs-client-relationship-summary.md (also .html, .pdf).
Missing: each prior version in effect during the review period.
Have: executed, signed advisory agreements for two recent new clients — Nash and Tilley (each also .html, .pdf).
Missing: the blank standard-form advisory agreement, and a representative sample across the review period — the two on hand are 2026 new-client agreements only.
Have: Code of Ethics policy memo; quarterly attestations for Q1 & Q2 2026 (11 files on Ellen's desk) + register attestations.csv (18 rows).
Missing: the personal-securities transaction and holdings reports of supervised persons.
The quiet majority, kept quiet so the holes stay loud. Each cites the office file or register that answers it.
| Item | Request (short) | Responsive records on hand |
|---|---|---|
| 3 | Client list w/ identifiers, type, custodian, billing value | households.csv (142 households) + accounts.csv (317 accounts — type, custodian, masked number, billing value) |
| 5 | Fee calculations & billing records, recent two quarters | billing-history.csv (2026-Q1 + Q2) + billing-history export + Q3 draft register + q3-fee-expected.csv |
| 6 | Fee schedule(s), incl. legacy/closed & discounts | fee-schedules.csv (standard tiered · legacy flat 0.90% · family-discount / householding) |
| 8 | Form CRS delivery evidence | CRS delivery log + crs-delivery.csv (139 households — version, date, method) |
Review-period note: the letter's stated period is 2022–2024; the office today holds 2026 records. The covered and partial items are answered by current-period records, not the 2022–2024 versions the letter asks for — a subtler gap worth Ellen's eye.
What it read: office/ (all six desks) and office/spine/*.csv (reference)
only — not the spine's working notes, the scan inbox, or anything outside the office · against the request list in
2024-05-06-exam-request-letter.md.
Full plan — every item, its status, and the files behind it: binder plan (2026-08-04).