For many registered investment advisers, the task of determining ongoing compliance requirements can seem overwhelming. Carrying out an investment adviser’s ongoing compliance duties can be a very manageable process if the investment adviser is aware of its requirements and organizes and assigns responsibilities for the various compliance functions. A compliance calendar can be a valuable tool to assist investment advisers in carrying out their ongoing compliance duties throughout the year. Developing a compliance calendar can help strengthen an investment adviser’s compliance program that must be developed to detect, prevent, and correct possible regulatory violations that can occur throughout the year.
As 2011 comes to an end, investment advisers should review their annual compliance calendars to determine if they should be updated or revised due to internal or regulatory changes that have occurred throughout the year. As your investment adviser develops its compliance calendar, it should consider including all items that should be completed on a monthly, quarterly, and annual basis. Investment advisers should not only think in terms of those items that the regulators have designated as tasks that should be completed each year such as the annual compliance review, annual renewals, or the annual Form ADV update filing but investment advisers should also consider those internal controls and checks that are in place to prevent and detect violations. The following are a few examples of things investment advisers should consider including on their compliance calendars:
- Ongoing reviews and monitoring for proper firm registration and investment adviser representative licensing
- Quarterly fee audits to check that client fees are being billed correctly
- Ongoing compliance training
- Due diligence reviews (e.g., solicitors, third party money managers, service providers)
Investment advisers should use their written compliance policies and procedures as their guide to begin developing a customized compliance calendar. A well written, customized compliance program should lay out the investment adviser’s ongoing compliance requirements and the systems and controls the investment adviser has in place to prevent, detect, and correct compliance violations. Compliance calendars can help to eliminate uncertainties about your investment adviser firm’s activities and can be a great way to preemptively prepare for the investment adviser’s annual compliance review.
As the year quickly comes to an end, make a resolution to prepare for 2012 by creating and implementing a compliance calendar for your investment adviser. For more information and for tips to assist your investment adviser in preparing its compliance calendar, RIA Compliance Consultants is hosting a webinar “Getting Your Compliance Calendar Ready for 2012,” to be held on December 8, 2011 at 12:00 CST. The fee for this webinar is $69.95 and it will last approximately one hour. To register, simply click here.
For more information on our services, click here to schedule a time to speak with one of our Senior Compliance Consultants.