Compliance packet · Printable Interactive version →
Onboarding Pipeline Packet

Velocity Capital — Client Onboarding

A walkthrough of every stop on the onboarding pipeline, the regulatory basis for each step, and the audit-trail evidence the system records. Suitable for handoff to internal audit or examiner review.

Document version 1 · Generated 2026-06-21
§ 1 — What this product is

A configurable, whitelabeled client onboarding platform for broker-dealers and RIAs.

One application replaces the patchwork of PDF forms, DocuSign envelopes, KYC vendor portals, and email approval threads that most firms still use. Compliance configures the flow per client type. Clients move through a guided wizard. Reviewers approve or reject from a single workbench. Every step is recorded as immutable audit evidence.

§ 2 — The six-stop pipeline

Invite → Wizard → KYC → eSign → Compliance Review → Activation

Each stop produces its own audit row. The application's full history is a deterministic sequence of those rows, joined by application_id.

§ 3 — Stop 1 · Invite

The client receives a one-time invite link tied to a specific client type.

Compliance dispatches the invite from the Admin Console. The link encodes the client type, the published configuration version, and a single-use token. Opening the link creates an applicant record and starts the session.

FINRA 4512(a)(1)(C) · Account opening trigger Account-opening data collection is timestamped from the moment the client begins the application — not when they submit it.
§ 4 — Stop 2 · Wizard

Nine steps for institutional clients; dynamic sequence for retail.

  1. Select Account Type
  2. Personal Information (AI-prefill)
  3. Employment & Financial Profile
  4. Trading Experience (options, margin)
  5. Identity Verification (Hyperverge KYC)
  6. Tax Certification (W-9 inline, W-8 routed)
  7. Regulatory Disclosures (Reg BI)
  8. eSign Documents (CleverAlpha eSign engine)
  9. Confirmation

Retail accounts use a separate wizard with dynamic step sequence based on account type: individual, joint (5 variants), UGMA, IRA. Joint accounts append a co-applicant flow; community-property joints append spousal consent; UGMA appends minor info.

§ 5 — Stop 3 · KYC

In-browser identity verification via Hyperverge.

Document capture → face match selfie → liveness check. Result returns synchronously. OFAC, PEP, and adverse-media screening run server-side. Hits route to enhanced due diligence in the Compliance Dashboard.

USA PATRIOT Act § 326 · Customer Identification Program Name, DOB, address, identification number, plus reasonable belief in the customer's identity. The Hyperverge result satisfies the reasonable-belief component.
§ 6 — Stop 4 · eSign

CleverAlpha's own eSign engine — not DocuSign.

Documents bound to each client type are signed in a single envelope. The signature pad captures stroke timing, IP, and user-agent. The completed envelope is sealed with a SHA-256 hash and written to immutable storage. Architectural choice: own the audit envelope, control the signature ceremony, avoid per-envelope vendor fees.

ESIGN Act (15 U.S.C. § 7001) · UETA Electronic signatures are legally equivalent to handwritten signatures when the signer intends to sign, consents to electronic signing, and the signature is associated with the record. The ceremony records all three.
§ 7 — Stop 5 · Compliance Review

One workbench, one decision per row.

The Compliance Dashboard is the principal's surface. Live counts of queue depth, filterable table, slide-out drawer for full applicant detail. Three terminal actions: Approve · Request Info · Reject. The Ops View is the same surface with decision controls removed — for SLA monitoring without approval authority.

FINRA 4512(c) · Principal approval No account may be opened without principal approval. Reviewer's identity, basis for approval, and timestamp are recorded as part of the immutable audit trail.
§ 8 — Stop 6 · Activation

Approval fires a chain of one-shot events.

§ 9 — Regulatory mapping

Every step ties to a documented rule.

Pipeline stopRuleWhat it requiresHow we satisfy it
Invite / WizardFINRA 4512Customer account information at openingSteps 2–4 collect & persist
WizardFINRA 2090Know Your CustomerStep 2 identity, step 3 financial profile
WizardFINRA 2111SuitabilityStep 3 + step 4 drive suitability profile
KYCPATRIOT Act § 326Customer Identification ProgramStep 5 Hyperverge in-browser verification
KYCBSA / OFACSanctions screeningOFAC, PEP, adverse-media screening on Step 5
TaxIRS § 1441 / FATCATax certificationStep 6 W-9 inline / W-8 routed
DisclosuresReg BIDisclosure ObligationStep 7 per-disclosure acknowledgment
eSignESIGN Act / UETAElectronic-signature equivalenceStep 8 signature ceremony + envelope hash
ReviewFINRA 4512(c)Principal approvalCompliance Dashboard approve action
AllSEC 17a-3 / 17a-4(f)Books and records, WORMHash-chained audit trail, 6-year retention
§ 10 — Audit trail summary

Six tables, joined by application_id, retained 6 years.