Client Complaints Policy Template for RIAs
Advisers Act Rules 204-2(a)(7) and 206(4)-7
What counts as a complaint, how staff report one, how it is investigated and answered, who can approve a settlement, and what is kept.
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What the rule requires
No SEC rule requires an adviser to keep a complaints log as such, unlike FINRA's rules for broker-dealers. Rule 204-2(a)(7) requires advisers to keep written communications about their advice, and complaints often fall within it. Examiners routinely ask how complaints are received, handled and reviewed.
Many state securities regulators do require state-registered advisers to keep complaint records, following the NASAA model rule.
What the policy covers
The sections of Luna's model Complaints policy. Your draft includes only the clauses that apply to your firm.
- 1Definition and reporting
- 2Handling
- 3Records and review
What Luna asks you
A few of the questions that shape the draft:
- Who receives and handles complaints
- How quickly a complaint is acknowledged
- Who must approve a settlement
- How often the complaint log is reviewed
How drafting works
- 01Answer questions about your firm
Plain questions about how you operate. Where there is a common answer, Luna suggests it; where you are not sure, say so and it is flagged rather than assumed.
- 02Luna drafts the policy
Only the clauses that apply to your firm, in your firm's name, each traced to the rule or choice it comes from.
- 03Review what is left
Anything unanswered is marked in the text and listed for you, and the policy cannot be approved until each is settled.
- 04Edit, approve and roll out
It is your policy: edit it like any other, approve it, and have employees acknowledge it in the same place.
Read the source
Other policies
A summary of what the rule requires, current as of October 2026, so you can see what the policy covers. It is not legal advice. A policy drafted in Luna is your firm's draft to review, edit and adopt.