Raffles Consulting Services

Family office adviser evidence request register

A family office evidence request register coordinates authority, secure delivery and closure without circulating the family’s full file.

A family office evidence request register should show exactly what each adviser requested, why it is needed, who may approve disclosure, where the source record sits and what proves delivery. It should not become a second archive of passports, bank statements, trust instruments and private agreements.

Different advisers have different legal and professional duties. A bank, fund manager, corporate service provider, accountant, tax adviser and lawyer may legitimately request overlapping information for different purposes. The register helps the family respond consistently while preserving each adviser’s independent judgement.

Log the request in the adviser’s own terms

Record the date, requesting organisation, named contact, affected entity or person, requested item and stated purpose. Preserve the original request in the secure matter file. Do not paraphrase a narrow request into a broad instruction such as send all wealth documents.

The Family Office and UHNW Advisory hub explains the wider governance context. The Singapore family office governance operating model remains the pillar cornerstone. Its authority map should determine who can release records and who handles unresolved questions.

Identify the evidence question before choosing a document

Ask what fact the adviser needs to establish. A registry extract may prove legal ownership. A sale agreement may explain a wealth event. A bank statement may trace a specific source of funds. A tax filing may support income or residency facts. One document should not be presented as proof of a fact it does not establish.

The ACRA guidelines for registered corporate service providers describe risk-based customer acceptance, independent and reliable evidence, authority checks and record keeping. They also show why a provider may require information beyond the family office’s ordinary governance file.

Register field Control question Closure evidence
Request What exact item or fact did the adviser request? Original dated request
Purpose Which entity, person, transaction or duty does it concern? Adviser clarification where needed
Authority Who may approve this disclosure? Mandate, delegation or consent
Source Is the record current, complete and independently reliable? Issuer and verification reference
Delivery Was the approved item sent through the correct secure route? Transfer receipt and access record
Outcome Did the adviser accept it or ask for more? Dated adviser response

Check authority for every disclosure

Identify the legal owner of the information and the person authorised to release it. A family principal’s instruction may not authorise disclosure of a company, trust, fund or beneficiary record. Check board authority, trustee powers, mandates, consent and professional restrictions as applicable.

Where an agent supplies information, retain evidence of the agent’s authority. The ACRA guidance expressly addresses authority evidence in customer acceptance. If authority is unclear, pause the request rather than asking an assistant to forward the file informally.

Use a source index instead of duplicating the archive

Give each source record a stable evidence identifier, issuer, date, subject, owner and secure location. The request register should point to that identifier. It may include a short status such as current, superseded, incomplete or awaiting certification, but should not reproduce sensitive contents.

Compare the chosen source with current official or independent records where appropriate. If the evidence conflicts with an earlier submission, open a discrepancy record and tell the adviser. Do not silently select the version that makes the request easiest to close.

Apply the smallest useful disclosure

Send only the approved information needed for the stated purpose. Redaction may be appropriate when it does not hide a material fact or prevent the adviser from meeting a duty. Ask the recipient before redacting a field that may be required for verification.

Use the approved secure channel, protect any transfer password separately and set an expiry where the system supports it. Do not put secrets, complete identity numbers or private bank records into ordinary task comments. Record delivery without copying the confidential contents into the log.

Respect each adviser’s independent obligations

The current accountants’ anti-money laundering rules illustrate duties relating to customer due diligence, doubts about earlier information, reliance on third parties, ongoing monitoring and record keeping. Other advisers operate under their own rules and risk frameworks.

A previous bank acceptance does not require another adviser to accept the same package. Likewise, a family office approval does not override a professional’s duty to request more information, decline reliance or report through a protected legal route. Record the outcome without trying to standardise independent decisions.

Track tax and family-office incentive requests separately

The MAS single-family-office guidance describes regulatory and notification matters for qualifying arrangements. Tax incentives, exemptions and annual returns can create their own evidence requests. Tag the relevant entity, assessment period and professional owner.

Do not describe a pending application, exemption position or adviser review as approved. The register should distinguish requested, supplied, accepted, queried and closed states. A received email is not necessarily acceptance of the underlying evidence.

Escalate overdue and conflicting requests

Set a due date based on the adviser’s deadline and the time needed for authority, certification or translation. If two advisers request inconsistent representations, preserve both and escalate the factual conflict. Do not provide different answers merely because their forms use different wording.

The source-of-wealth evidence change-control guide provides a related method for updates. Use a formal discrepancy escalation when facts cannot be reconciled or when a regulated professional identifies a material concern.

Close the family office evidence request register

Delivery closes the sending step, not the request. Ask whether the adviser accepted the evidence, needs clarification or has imposed a condition. Record that response and update any recurring due date. Keep unresolved requests visible to the accountable family-office officer.

A family office adviser evidence request register gives the family one disciplined view of requests without creating one uncontrolled pool of private material. It connects purpose, authority, source, secure delivery and adviser outcome, while leaving each professional responsible for the decision that belongs to that role.