Customized Compliance Program
for Existing Registered Investment Advisor
RIA Compliance Consultants can create and implement a customized and more
comprehensive compliance program for your registered investment advisor firm. The
following are services that RIA Compliance Consultants can tailor for inclusion
in your investment advisor’s compliance program.
- Calendar, Reminders, Checklists & Forms. Develop a
pro-active compliance calendar, supervisory reminders, checklists, and forms
for the purpose of executing and documenting your registered investment advisor’s
supervisory procedures/compliance program.
- Code of Ethics & Supervisory Procedures. Prepare,
modify and/or update the code of ethics, compliance policies and written
supervisory procedures in conformance with the actual business model of your
registered investment advisor.
- Form ADV. Review your registered investment advisor
firm’s organizational structure, leadership, business model, investment
advisory activities, activities of related persons, potential conflicts of
interests, regulatory history and compliance practices. Revise and
update the Form ADV of your investment advisor based on such review. Create
and maintain a master log summarizing all amendments and other changes to
the Form ADV of your investment advisor.
- Client Brochure. Create a client brochure in lieu
of a Form ADV Part II and Schedule F.
- Solicitor Disclosures. Develop
due diligence/supervisory procedures and documents for selection of solicitors,
separate solicitor disclosure statement for referred clients, and solicitor
disclosure language for Form ADV Schedule F.
- Wrap Program. Prepare or revise a Schedule H client
brochure describing your investment advisor’s wrap-fee program and
any other necessary modifications or additional disclosure language to the
Form ADV. Develop compliance policies and procedures for your investment
advisor to supervise its wrap-fee program.
- IARD Service Bureau. Handle
filing amendments to Form ADV Part 1, upload of Form ADV Part II, amendments
to Form U4 and Form U5 of investment advisor representatives, state notice
filings, and annual investment advisor registration renewals through the
IARD/CRD systems.
- IAR Registration Analysis. Study
job descriptions, activities and location of associated persons of the registered
investment advisor and recommend investment advisor representative registration
when and where appropriate.
- Annual ADV Offering & Privacy Policy
Delivery. Prepare
annual Form ADV offer letter and privacy policy delivery letter to investment
advisory clients.
- Advertising Review. Analyze proposed
advertising materials (including company website) and provide written comments
and revisions in accordance with the advertising standards imposed by the
SEC for investment advisors.
- Fee Audit. Conduct an
audit of the investment advisory fee authorizations, calculations and debits
by your investment advisor firm.
- Form 13F & Schedule 13G. Provide
assistance with preparing and submitting Form13F and Schedule 13G filings
via EDGAR.
- Personal Securities Transactions. Assist
with review of quarterly personal securities transactions and annual holding
reports of investment advisor representatives in relation to trading recommendations
and activity and restricted list of your investment advisor firm.
- Best Execution. Provide
qualitative analysis of whether your investment advisory clients are receiving
best execution from its custodians in accordance with the SEC requirements
and prepare written report.
- Compliance Training. Conduct
regular investment advisor compliance training for investment advisor representatives
and other associated persons through on-site visits or by telephone/webinar.
- Compliance Committee Meetings. Participate
(via telephone) in monthly compliance committee meetings of your investment
advisor.
- Consulting. Provide consulting to your investment
advisor regarding investment advisory compliance issues on an as-requested
basis.
- Annual Review/Compliance Assessment. Conduct annual
compliance assessment and prepare a report regarding the adequacy of the
investment advisor’s code of ethics, compliance policies and supervisory
procedures, and the effectiveness of the implementation of such policies
and procedures.
- Mock Exam. Conduct a mock SEC examination of your
investment advisor. Visit your investment advisor’s primary office
for two days. Conduct interviews of key personnel and principals of
your investment advisor. Review a sampling of the investment advisory
documents likely to be requested by the SEC. Prepare a written report
of findings.
Please contact RIA Compliance Consultants to set up an appointment to discuss
the specific compliance opportunities and challenges facing your registered
investment advisor firm. We then can prepare an annual compliance program proposal
that will meet the needs of your investment advisor firm.
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