In September 2017, The North American Securities Administrators Association (NASAA) released its 2017 Investment Adviser Coordinated Examinations Report. NASAA’s report looked at 1,227 routine investment adviser examinations of state registered investment advisers. Once again, the area with the most deficiencies was books and records. Almost two out of every three investment advisers examined (64.6%) reported a deficiency in books and records retention.
Under Rule 204-2, the “Books and Records Rule,” of the Investment Advisers Act of 1940 every investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”) must make and keep true, accurate, and current certain books and records relating to its investment advisory business. Most state securities regulators have the same or similar record keeping requirements. All records required to be maintained by investment advisers under the Books and Records Rule or similar state securities regulations are subject to examinations by the SEC or state securities examiners.
RIA Compliance Consultants has a variety of sample forms to assist your investment adviser with maintaining the appropriate books and records including: a sample books and records documentation logs and suggested list of compliance files and reports, sample annual compliance calendar checklist, sample compliance training/meeting attendance sign-in form, sample compliance violations reporting form, and sample compliance manual acknowledgement form. For a complete list of our available sample forms, click here. These Sample Forms may be available through your Annual Compliance Program Package