“We have provided a short summary of our services. Please note, however, that the list below is not all-inclusive. We customize our services to fit your firm’s individual compliance needs.”
Investment Adviser Written Supervisory Procedures Manual, including Monthly Compliance Checklist
Creating and maintaining a supervisory compliance policies and procedures manual that accurately reflects how you comply with regulatory requirements is a vital part of demonstrating compliance. Utilizing an efficient information-gathering process, we create and customize your compliance procedures by detailing the firm’s internal procedures and how the everyday practices comply with state and SEC regulations.
The Advisers Act requires all investment advisers to develop and implement compliance programs. These compliance programs must include written policies and procedures reasonably designed to prevent violation of the Advisers Act.
Written investment adviser compliance procedures should include, at a minimum, the following areas:
Portfolio management processes
Creation and maintenance of required records
Trading practices
Personal trading activities of supervised persons
The accuracy of disclosures made to investors, including information in Form ADV and advertisements in print and on the web
Safeguarding client assets
Marketing advisory services, including the use of solicitors
Safeguards for the protection of client records and information
Our procedures are updated as needed throughout the year to reflect changes in industry best practices. We also stay abreast of new SEC and State rules and investment adviser regulatory requirements so that we only offer up-to-date advice to ensure that your firm maintains compliance with new rules and regulations as they occur.
In addition to the compliance manual, we can also provide a Compliance Checklist to review monthly which will help streamline and manage your compliance responsibilities throughout the year.
Code of Ethics
The SEC sets forth guidelines for the code of ethics. Many states follow the SEC guidelines for maintaining a written code of ethics and have the same requirements as the SEC. The Advisers Act requires each federally registered investment adviser to adopt and maintain a written code of ethics. The code of ethics sets forth a standard for business conduct that the investment adviser adheres to and requires of all persons under their supervision. Investment Advisor Compliance Solutions can provide you with a template that meets both state and SEC requirements.
Advertising/Performance Reviews
The SEC and other regulators are placing increased focus on marketing and performance information, including preparation, reporting and footnoting. Investment Advisor Compliance Solutions will review your advertising and performance presentations, including your website and performance data, and make recommendations for proper and appropriate procedures and disclosures to bring you in line with SEC and state investment adviser regulatory requirements.
Mock SEC/State Examinations
Investment Advisor Compliance Solutions can examine your firm for compliance with SEC requirements and, if requested, issue a confidential report to management outlining the examination findings with recommendations for corrective action. In addition, Investment Advisor Compliance Solutions can assist in creating solutions to the issues identified in the examination. If your firm falls under state regulation our examination can be designed to address the rules of the applicable state(s). The examinations generally cover the following areas:
Form ADV/Brochure Disclosure and Delivery
Privacy Policies
Client Agreements, including Solicitor Agreements and Disclosure Documents
Brokerage Practices, including Aggregation and Allocation Policies
Compensation / Client Fees
Custody of Client Funds and Securities
Internal Controls
Conflicts of Interest
Insider Trading Policies
Advertising, including Marketing/Performance Presentations and Website review
Wrap Fee Programs
Books and Records
Proxy Voting Policies
Business Continuity Planning
Off-site Compliance Review
Investment Advisor Compliance Solutions offers an off-site compliance review – similar to the Mock SEC Examination. This service is offered to provide a cost effective alternative to an on-site Mock Exam. Investment Advisor Compliance Solutions will request certain documents, and upon review and discussion, issue a confidential report to management outlining our examination findings with recommendations for corrective action. Investment Advisor Compliance Solutions will help identify potential problems so that you have the time to correct them before the regulators arrive.
Annual Compliance Reviews
Investment Advisor Compliance Solutions will assist your firm in conducting an annual compliance assessment and prepare a report addressing the adequacy of your Compliance Program and any risks or potential conflicts of interest. The SEC Compliance Program Rule requires each federally registered adviser to review its compliance policies and procedures at least annually to determine the adequacy and effectiveness of their implementation.
Business Continuity Plans
Business Continuity Plans establish emergency preparedness policies and procedures in the event of a significant business disruption (SBD). SEC compliance requires that investment advisers maintain a Business Continuity Plan as part of an effective Compliance Program. Investment Advisor Compliance Solutions will assist you with the customization of the document and have developed a template for a Business Continuity Plan to help you comply with the Rule.
General Consulting
Our professionals have in-depth expertise regarding investment adviser regulatory requirements and broad experience in the investment adviser industry. We understand the enormous demands made on today’s investment advisory firm managers - time is money and both are valuable.
Let our team of professionals take on the task for your firm without the unnecessary expense of training and maintaining in-house staff. This will allow you to focus on your core business objectives – offering your clients high quality investment products and marketing your business.
When you use our consulting services you will be assured that your compliance obligations are being met and your firm is in full legal compliance with investment adviser regulatory requirements.
Investment Advisor Compliance Solutions provides the following compliance consulting services:
Assistance with review and analysis of regulatory inquiries
Assistance with monthly, quarterly and annual filing deadlines
Assistance with compliance matters that may arise during the course of the business day
Updates on new and amended rules
Research and answers to specific investment adviser compliance questions
Research and answers to specific investment adviser registration questions
Assistance with marketing and answers any marketing compliance concerns
