diff --git a/TODO.md b/TODO.md
index 9329bde..b6b8a25 100644
--- a/TODO.md
+++ b/TODO.md
@@ -198,6 +198,70 @@ Cache store reads entire files into memory (`readFileAlloc` with 50MB limit).
 For portfolios with 10+ years of daily candles, this could use significant
 memory. Keep current approach unless memory becomes a real problem.
 
+## Audit: manual-check accounts mechanism (NYL, Kelly's ESPP, etc.)
+
+Some accounts/positions can't be reconciled from broker CSVs and need a
+human-in-the-loop reminder at the audit step. Examples:
+
+- **NY Life** — no CSV export at all. Values only live in periodic
+  statements.
+- **Kelly's ESPP** — accrued payroll-deduction cash doesn't appear in the
+  Fidelity positions CSV until the purchase date hits (typically every
+  6 months). Between purchases the cash is a real contribution that
+  `zfin audit` can't see.
+- Future: treat as an open category.
+
+The existing `update_cadence::weekly|monthly|quarterly|none` field already
+sort-of covers this, but has two gaps:
+
+1. It fires off the last *git-detected change*, not the last *human
+   review*. For NYL, the value sometimes hasn't changed in months — so
+   git never fires, cadence never trips.
+2. ESPP needs weekly-ish attention while accumulating cash between
+   purchases, but the accrued balance is invisible to the CSV audit.
+
+### Options
+
+A. **New `update_cadence::manual` variant** — always fires every audit
+   run until silenced. Blunt but zero design work.
+
+B. **`last_refreshed::YYYY-MM-DD` field on `accounts.srf`** — explicit
+   human-review timestamp, decoupled from git-detected changes. Audit
+   compares `today - last_refreshed` against the cadence. User bumps
+   the field when they check the statement. Probably the most
+   correct fit for NYL.
+
+C. **Sticky TODO list** — a `todos.srf` or `todo::` field on accounts
+   that audit always surfaces until cleared. General-purpose; also
+   covers "remember to rebalance on 5/15".
+
+### ESPP-specific follow-through
+
+ESPP is also a contribution-attribution blind spot. If Kelly's paystub
+deducts $X/week but the cash lot doesn't reach `portfolio.srf` until
+the purchase date, the attribution math is under-counting contributions
+and over-counting the purchase-week gain. Possible fixes are discussed
+in the "Contributions diff" TODO below — option C there (per-account
+`cash_is_contribution`) would make manually-entered ESPP
+cash additions count correctly.
+
+## Audit: tax-loss account persistent discrepancy (~-$897.59)
+
+The tax-loss account consistently shows a small discrepancy (around
+-$897.59 at time of writing) that requires manual tweaking in the
+ratio-updates section — either adjusting shares or `price_ratio` each
+week. The account is a weird one and requires careful hand-updating;
+not something the runbook can safely automate.
+
+Consider introducing an **"expected discrepancy tolerance"** field per
+account so audit only flags deltas exceeding the known drift. Would
+keep the audit output signal-to-noise high for this and any other
+accounts with known-unfixable drift.
+
+Careful: a tolerance should never silently swallow real discrepancies.
+Probably render as muted (still visible, just not warning-colored)
+until the delta exceeds the tolerance, rather than filtering entirely.
+
 ## Torn SRF files from server sync (recurring bug)
 
 **Status:** First-layer fix done — 2026-05-02. `syncFromServer`
@@ -214,4 +278,3 @@ will try the provider fallback.
 - Read-path self-heal: on SRF parse failure during read, invalidate
   the cache entry so a subsequent refresh can repair without user
   intervention.
-