Your 2026 Rollover Compliance Workflow: A Step-by-Step Process Advisors Can Actually Follow
Advisors everywhere know: rollover compliance in 2026 is no longer a nice-to-have, it's a non-negotiable. The DOL and SEC have raised the bar, and regulators are demanding clear, repeatable, audit-ready processes behind every recommendation. If you want to survive and thrive amid evolving expectations, you need an approach that's streamlined, defensible, and professionally documented. In this blog, we'll walk you through a real, step-by-step rollover compliance workflow that busy advisors (like us) can actually follow. You'll see why Simple Advisor Tools focuses on efficiency without sacrificing rigor, and how you can build a bulletproof workflow for 2026 and beyond.
Why a Detailed, Documented Rollover Compliance Workflow Matters in 2026
Regulators are focusing sharply on rollover recommendations — with both the SEC's exam priorities and PTE 2020-02 mandating best interest analysis, careful documentation, comparison of alternatives, and robust disclosure. Spreadsheets and sticky notes just don't cut it anymore. We've seen firsthand how examiners demand proof in the form of side-by-side analyses, audit trails, and written justifications. Noncompliance risks are real: loss of compensation, hefty civil penalties, and reputational harm.
And here's the thing: with the right workflow, the manual, 6+ hour slog can become a focused, 12-15 minute process that is more consistent and more defensible every time.
Step 1: Gather Core Client Information and Select Analysis Type
Start by capturing complete details about the client and the context:
- Client Profile: Age, goals, time horizon, risk tolerance, and any unique liquidity or withdrawal needs.
- Compensation and Service Structure: How you are paid for this engagement, what services you will provide, any potential conflicts of interest.
- Type of Rollover: Identify whether you're assessing a Plan-to-IRA, IRA-to-IRA, or Plan-to-Plan scenario. Each has distinct documentation and comparison requirements for compliance.
Pro tip: Matching the client's investment profile to Reg BI and PTE 2020-02 best interest requirements isn't optional. This alignment should drive your analysis from the very beginning.
Step 2: Collect Plan Data and Required Disclosures
Objective, auditable data is the backbone of all compliant rollover analyses. Here's how we pull it together efficiently:
- Form 5500 Database: Search over 500,000 employer plans by company name. Instantly retrieve the plan's admin fees, participant counts, investment expense ratios, and assets from Department of Labor filings.
- Fee Disclosures: Upload participant fee disclosure documents or enter fees manually for non-standard or missing plans.
- Benchmarking and Comparisons: For IRAs, use established industry benchmarks and tool-identified cost ranges to set a defensible reference point.
This approach drastically shrinks research time and provides the traceable data regulators expect. According to Simple Advisor Tools, accessing directly integrated datasets reduces data gathering from hours to just five minutes on average.
Step 3: Analyze Fees, Investment Options, and Services — Side by Side
Now, turn raw data into actionable recommendations. This step is where your value as an independent advisor is truly demonstrated:
- Fee Analysis: Present clear side-by-side comparisons of administrative fees, expense ratios, and any advisory costs.
- Investment Access: List range and types of available funds or investment vehicles in both the current plan and proposed IRA.
- Service Comparison: Clarify the scope of services available to the client, such as personal advice, tax/estate planning, digital access, or educational tools.
- Conflict Disclosure: Identify and clearly document any compensation differences or other potential conflicts relevant to your recommendation.
- Weighted Scoring (Optional): Use weighting based on client priorities if relevant. For example, if investment variety matters most, visually emphasize differences here.
Document why your recommendation truly aligns with the client's best interest, and leave a clear record of how you weighed reasonably available alternatives—as required by Reg BI and the DOL.
Step 4: Generate Audit-Ready Reports and Required Disclosures
With your robust comparison in hand, produce a professional, compliant report. Your file should include:
- Overview and summary of the client's situation and all options analyzed
- Fee, expense, and service comparison tables and charts
- Mandatory PTE 2020-02 disclosures (fiduciary status, all conflicts, description of Impartial Conduct Standards)
- Detailed documentation of your analysis process, findings, and client acknowledgments
- Audit trail and secure electronic retention for at least seven years, as required by DOL regulation
Regulators want to see that your recommendation wasn't just a one-off but part of a documented, repeatable process. Simple Advisor Tools provides these features out of the box, allowing us to generate reports in just 10-15 minutes -- an enormous savings over manual preparation. See our comparison of manual vs automated rollover workflows for more detail on the time and risk savings.
Ongoing: Perform and Document Annual Retrospective Reviews
PTE 2020-02 doesn't stop after the initial report. Advisors must conduct an annual review of their rollover recommendations, verifying that best interest standards are continuously met and that patterns of risk (such as repeated recommendations of high-fee IRAs) are identified and addressed. Compliance tools simplify this by flagging outliers and creating executive-ready review documents, but whatever your process, you need documentation to support that a senior officer or committee has reviewed findings annually.
Manual vs Automated: Why Workflow Choice Matters
Here's an at-a-glance summary of how a best-in-class automated workflow, like Simple Advisor Tools, compares to manual prep:
| Process | Manual (Typical Time) | Automated (Typical Time) |
|---|---|---|
| Data Gathering | 2–3 hours | 5 minutes |
| Fee and Service Analysis | 1–2 hours | 2 minutes |
| Documentation and Disclosures | 2–4 hours | 3 minutes |
| Annual Review Prep | Several days | 30–60 minutes |
| Total Per Rollover | 6–11 hours | 10–15 minutes |
These time savings aren't just about efficiency—they're about delivering more value to clients, reducing compliance risk, and freeing up capacity to serve more households at a high level. If you want to dig deep into the compliance risks associated with a manual process, our detailed guide on manual versus automated rollover analysis is a must-read.
Beyond the Checklist: What Distinguishes a Truly Audit-Ready Workflow?
It's easy to focus only on the mechanics, but as practitioners, our experience is that examiners care about:
- Consistency — Every rollover is handled the same way, every time
- Objectivity — Comparisons reflect real fee/service differences, not subjective opinions
- Transparency — Clients and regulators see how and why you arrived at the recommendation
- Traceability — The analysis and recommendation can be reconstructed from your records, even years later
Modern compliance-ready platforms, like Simple Advisor Tools, empower you here with audit-ready reports, repeatable workflows, and secure, long-term data retention. But even if you're using manual systems, an unwavering focus on these pillars is crucial for regulatory trust in 2026.
Final Thoughts: Setting Your Practice Up for Success
The leap from reactive compliance to proactive, audit-ready documentation may seem daunting, but the reality is that modern tools and workflows put this fully within reach. Advisors (from solo practitioners to broker-dealer teams) can now blend deep expertise with institutional-grade process—yielding better outcomes for clients and ready answers for regulators who are no longer taking shortcuts.
Start with a single workflow, scale it across your practice, and keep iterating. If you're considering software to power your process, a transparent, trial-based approach (no contracts or sales hoops) lets you evaluate whether something like Simple Advisor Tools fits your style and needs.
Ready to Future-Proof Your Rollover Process?
If you want a trusted resource for making your rollover compliance workflow streamlined, scalable, and defensible in 2026, Simple Advisor Tools is designed specifically for independent advisors, compliance teams, and broker-dealers. Try it risk-free or dive into our resources for deeper guidance. You can start a 14-day free trial instantly — no credit card or sales call required.
Want more insights on practical compliance? Explore our other resource, What Financial Advisors Need to Know About PTE 2020-02 Fiduciary Documentation Requirements, for a step-by-step look at your obligations.
If you found this guide helpful, share it with your compliance team or fellow advisors—empowering each other is how our profession gets better and stronger for the long-term.
Put Your Knowledge Into Practice
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