Knowledge Base
Can my firm register as an investment advisor without an individual qualified to serve as an investment advisor representative?
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2023 ADV Annual Amendment Questionnaire
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Compliance Calendar
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Compliance Manual - Updates/Sample Sections
- WSP/CoE Section - Advertising (Initially posted 10/20/2022)
- WSP/CoE Section Update - IAR CE (Last Updated in May 2022)
- Communicating with the Press/News Media (Last updated November 2021)
- Protecting Older and Vulnerable Clients with Diminished Capacity (Updated in June 2021)
- IRA Rollover Recommendation (Last Updated May 2021)
- New York IAR Licensing (Posted in February 2021)
- Section 13 Filings (Updated in December 2020)
- Form ADV Part 3 (Posted in May 2020)
- Account Type Suitability (Wrap vs. Non-Wrap Account) (Updated in April 2018)
- Mutual Fund Share Class Selection (Initially posted March 2018)
- Wrap v. Non-Wrap Account (Last Updated in March 2018)
- Non-Licensed Owner of RIA (Updated in February 2018)
- Participation on Investors Committee by Supervised Person (Posted in February 2018)
- Succession Plan (Posted February 2018)
- Insurance Agent (Not IAR Licensed) Attending Client Meeting (Posted in December 2017)
- Non-Licensed Meeting Attendee - Acknowledgement (Last updated in December 2017)
- Reports to Parent Company's President Do Not Trigger Supervised Person nor IAR (Posted in December 2017)
- Identity Theft & Wire Fraud (Last updated in July 2017)
- Text Messaging Permitted (Last Updated in July 2017)
- Account Type Suitability (Commission vs. Fee) (Last updated in June 2017)
- Different Fee Rates for Asset Classes in Retirement Accounts (Last Updated in June 2017)
- Inverse & Leveraged ETFs (Last updated in June 2017)
- Recommending FIA in lieu of SMA Retirement Account (Last Updated in June 2017)
- Text Messaging Prohibited (Last updated in June 2017)
- WSP/CoE Section Update – IRA Rollover Recommendations
- Sample WSP/CoE Section - Communicating with Press/News Media
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Compliance Review
- Compliance Review - Section 1 - Registration, IA Reps & Notice Filing
- Compliance Review - Section 2 - Written Code of Ethics, Personal Securities Transactions & Insider Trading
- Compliance Review - Section 3 - Branch Audit, Outside Business Activities & Supervision
- Compliance Review - Section 4 - Organizational Records & Operational Records
- Compliance Review - Section 5 - Proxy Voting & Foreign Clients
- Compliance Review - Section 6 - Privacy Policy, Electronic Communications & Electronic Storage
- Compliance Review - Section 7 - Business Continuity Plan & Information Security
- Compliance Review - Section 8 - Trading Records, Portfolio Management Records & Financial Planning
- Compliance Review - Section 9 - Service Providers, Utilizing Solicitors & Serving as a Solicitor
- Compliance Review - Section 10 - Regulatory Exams, Regulatory Investigations, Complaints & Whistleblowers
- Compliance Review - Section 11 - Fees & Custody, Advertising, & Social Media
- Compliance Review - Section 12 - Client Documents, Private Funds & ERISA
- Compliance Review - Section 13 - Wrap Fee Program
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Conference
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- Session 1: Investment Advisers Act Rule 206(4)-1 - Amendments to Advertising/Marketing Rules
- Session 2: IRA Rollovers - Conducting PTE 2020-02's Required Retrospective Review
- Session 3: Form ADV - Keeping It Fresh
- Session 4: Information Technology & Disaster Recovery/Cybersecurity
- Session 5: Common IA Exam Issues Through the Eyes of a Former Regulator
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FAQ
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- Are there any exclusions to the personal securities holdings and transaction reporting requirements of access persons of a SEC registered investment adviser?
- Are there any specific personal securities reporting requirements of a SEC registered investment adviser related to the SEC Rule 204A-1?
- Are there any specific requirements relating to violations of a SEC registered investment adviser's code of ethics?
- Can a SEC registered investment adviser accept confirmations and statements in lieu of a personal securities transaction report by the access person?
- Does a registered investment adviser have to obtain personal securities holding and transaction reports if the access person does not have any reportable securities holdings or transactions?
- Does a SEC registered investment adviser have to maintain a code of ethics?
- Does a state registered investment adviser have to maintain a code of ethics?
- If a SEC registered investment adviser only has one access person, must the access person complete personal securities transaction and holdings reports?
- Other than the requirements of the Rule, what else should be considered or included by an investment adviser when drafting a code of ethics?
- What are the recordkeeping requirements of an SEC registered investment adviser related to the SEC's Code of Ethics rule?
- What information must be included in the personal securities holdings report of an access person of an SEC registered investment adviser?
- What information must be included in the personal securities transactions reports of an access person of an SEC registered investment adviser?
- What is a reportable security for purposes of a personal securities transaction or holding report of an access person of a SEC registered investment adviser?
- What is beneficial ownership by an access person of a SEC registered investment adviser for personal securities transaction purposes?
- What must be included in a SEC registered investment adviser’s code of ethics?
- Who is considered a “supervised person” of a SEC registered investment adviser?
- Who is considered an “access person” of a SEC registered investment adviser?
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- Are the exemptions mandatory?
- Are there any exemptions to the registration requirements?
- Are there any reporting requirements for exempt advisers?
- How long will the registration process take?
- How much are the fees for filing as an investment adviser with the SEC?
- What is considered a private fund for purposes of the Advisers Act?
- When did the new rules become effective?
- When registering, what type of information will advisers have to provide about the private funds they manage?
- Who must file Form PF?
- Why is the SEC requiring private fund advisers to register?
- Will advisers need written compliance manuals?
- Will the individuals at the firm need to register as investment adviser representatives?
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- How do I file a report through EDGAR?
- How do I know if my registered investment advisor must file Form 13F?
- How frequently must Form 13F be filed?
- How is Form 13F, Schedule 13D and Schedule 13G submitted?
- What are the deadlines?
- What is required under Section 13(d)?
- What is required under Section 13(f)?
- What is required under Section 13(g)?
- What is required under Section 13(h)?
- What is the Form SH?
- What is the purpose of Form 13F?
- What must be reported?
- Where can I find more information about the requirements of Section 13(f)?
- Where can I find more information?
- Where can I view Form 13F?
- Where can I view the Section 13(f) securities?
- Who meets the definition of an institutional investment manager?
- Will the amount of assets under management reported on my registered investment advisor firm’s Form ADV Part 1 be the same amount reported on Form 13F?
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- How do you file Form PF?
- What are the compliance dates for Form PF?
- What are the fees associated with filing Form PF?
- What is the difference between a "small" and a "large" private fund adviser?
- What is the purpose of Form PF?
- When does Form PF have to be updated?
- Who is required to file Form PF?
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- Are there state securities regulators that do not require filing a Form U4 for registration of an Investment Adviser Representative?
- Do state securities regulators require an individual applying to register as an Investment Adviser Representative to submit a fingerprint card?
- How does an Investment Adviser Representative submit a Form U4?
- Is the information on the Form U4 available to the public?
- What happens if the individual registering as an Investment Adviser Representative has a “yes” answer/disclosure event on the Form U4?
- What happens to the Form U4 if an Investment Adviser Representative leaves a registered investment advisor firm and starts at another investment advisor firm?
- What information does an Investment Adviser Representative include on his or her Form U4?
- What is a Form U4?
- What is a Form U5?
- When does an Investment Adviser Representative file an initial Form U4?
- When does an Investment Adviser Representative need to update a Form U4?
- Reviewing & Updating Form U4 & Form ADV Part 2B - 6/23/2022
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- Are investment advisors subject to any net worth/net capital or bonding requirements?
- Can I start the investment advisor registration process if my entity isn’t established yet?
- Can my firm register as an investment advisor without an individual qualified to serve as an investment advisor representative?
- Do I personally register as an investment advisor or should I establish a corporation or limited liability company?
- Does an individual have to be sponsored by an investment advisor in order to take the Series 65 examination?
- Does an SEC registered firm have to register with a state?
- Explain the investment advisor registration process? How do I become a registered investment advisor (“RIA”)?
- How can an individual obtain a study guide to the Series 65 examination?
- How does a state registered investment advisor firm determine in which states it should be registered?
- How does an investment advisor firm obtain a surety bond to meet the state’s net worth requirement?
- How is an IARD/Web CRD account established?
- How long does the registration process take?
- How much are the registration fees to become registered as an investment advisor?
- How often are investment advisor registrations renewed?
- If my firm is registered with the SEC, do I need to personally register as an IAR?
- Is an individual serving as the chief compliance officer (“CCO”) of an investment advisor firm registered with the U.S. Securities and Exchange Commission (“SEC”) required to be registered with a state securities regulator as an investment adviser representative?
- Is the ADV Part 2 filed on-line?
- Is there a substantive difference between the terms "investment adviser" and "investment advisor"?
- Should my firm register with the U.S. Securities and Exchange Commission ("SEC") or with a state securities regulator as an investment advisor?
- What are the qualifications to register as an IAR?
- What happens if a new firm without any AUM registers as an investment advisor with the SEC and fails to acquire at least $100 million of AUM within 120 days of the effective date of the investment advisor registration?
- What is an “RIA”?
- What topics are tested on the Series 65 examination?
- What’s a Form ADV? What type of information is disclosed through the ADV?
- What’s an investment advisor representative?
- What’s an investment advisor?
- When does the Form ADV have to be amended?
- Will my investment advisor firm need to implement written compliance programs?
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- Are any individuals “grandfathered” from the requirement that an investment advisor representative must successfully complete Series 65 examination?
- Are there any prerequisites for taking the Series 65 examination?
- Are there refunds for canceling your Series 65 examination?
- Do I have to be sponsored by a registered investment advisor firm in order to take the Series 65 examination?
- Do I have to re-take the Series 65 examination if I previously passed the Series 65 but have not been affiliated with an investment advisor for over two years?
- How do I sign up for the Series 65 examination?
- How high of a score do I need on practice tests before taking the actual Series 65 examination?
- How long do I have to take the Series 65 exam after opening up my window?
- How long is the Series 65 examination?
- How many hours of study does it take to prepare for the Series 65 examination?
- How many times can I take the Series 65 examination?
- How much does it cost to take the Series 65 exam?
- If I have the Series 7 and Series 66, do I need to take the Series 65 examination?
- If I pass the Series 65 examination, can I start acting as an investment advisor?
- Is an individual acting as a solicitor required to pass the Series 65 examination?
- Is the Series 65 examination open book?
- Is there any other basis for an investment advisor representative candidate to obtain a waiver of the Series 65 examination requirement?
- On the day of the Series 65 examination, what do I take to the testing site?
- s the Series 65 examination on paper or computer?
- What are common mistakes when taking the Series 65 examination?
- What days of the week can I take the Series 65 exam?
- What happens if I fail the Series 65 examination?
- What happens if my window for taking the Series 65 expires before I schedule/take the exam?
- What is a passing score of the Series 65 examination?
- What is an effective way to study for the Series 65 examination?
- What topics does the Series 65 examination cover?
- What types of questions are included on the Series 65 examination?
- When will I learn of my results after taking the Series 65 examination?
- When would an investment adviser representative take or rely upon the Series 66 examination instead of the Series 65 examination?
- Where is the Series 65 exam held?
- Who administers the Series 65 examination?
- Who needs to take the Series 65 examination?
- Will my professional designation serve as an alternative to taking the Series 65 examination?
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- Are there individuals that cannot serve as a solicitor on behalf of a registered investment adviser under SEC Rule 206(4)-3?
- Can a solicitor provide investment advice to a client about a security and/or the securities market?
- Can the third-party solicitor’s referral fee be paid from the investment advisory fee charged by the registered investment adviser?
- Does a third-party solicitor have to be registered as an investment adviser or investment adviser representative?
- If a state securities regulator requires an individual to be registered as an investment adviser representative in order to solicit investment advisory clients in a third-party capacity, does the solicitor have to be an investment adviser representative under the investment advisor firm receiving such referrals?
- Is a solicitor required to provide a client with a separate written solicitor disclosure when the registered investment adviser firm gives impersonal advisory services?
- May an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) pay a third-party (non-employee) to solicit or refer new investment advisory clients?
- Should there be a specific disclosure within the Form ADV if a registered investment adviser pays a referral fee to a third-party solicitor?
- What are the basic regulatory requirements for a solicitor referral arrangement between an SEC registered investment adviser and a third-party (non-employee)?
- What information must be included in the separate written solicitor disclosure that the third-party solicitor must provide a client?
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- Are there any changes to the information asked in the Form ADV Part 1?
- Are there fees for filing as an investment advisor with a state securities regulator?
- Can a mid-sized investment advisor withdraw its registration as investment advisor from the SEC once it is registered as an investment advisor with the required state securities regulators?
- Does an investment advisor need $100 million or more of assets under management to register as an investment advisor with the SEC?
- How does an existing investment advisor let the applicable securities regulators know whether the investment advisor is required to register with the state securities regulator or remain registered with the SEC?
- What is a mid-sized investment advisor and under which securities regulator will a mid-sized investment advisor now register?
- What is the reason for the SEC switching the regulatory jurisdiction of mid-sized investment advisors from the SEC to state securities regulators?
- When can a mid-sized investment advisor start registering with state securities regulators?
- When did the SEC´s new switch rules for mid-sized investment advisors become effective?
- Will investment advisor representatives have to file Form U4 amendments?
- Will investment advisors still calculate assets under management in a manner similar to current requirements?
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- Are there any special books and records requirements specifically related to SEC Rule 206(4)-7?
- How does a registered investment adviser determine what needs to be included in its written supervisory and compliance policies and procedures?
- If a registered investment adviser purchases an off-the-shelf investment adviser compliance manual, will this meet the requirements of SEC Rule 206(4)-7?
- Is a registered investment adviser firm with only one investment adviser representative and no other employees required to maintain written supervisory and compliance policies and procedures?
- Is a state registered investment adviser required to maintain written compliance policies and procedures?
- Is an SEC registered investment adviser required to maintain written supervisory and compliance procedures?
- Once a registered investment adviser has developed written supervisory and compliance policies and procedures, what happens?
- What must be covered in an SEC registered investment adviser’s written supervisory and compliance policies and procedures?
- Who should an SEC registered investment adviser designate as a chief compliance officer (“CCO”)?
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Recorded Webinar
- 2023 Investment Adviser Exam Priorities - 2/23/2023
- CCO Basic Training - 2/2/2023
- 2022 Year-End Review - 12/1/2022
- Preparing for Compliance with SEC's New Marketing Rule - 10/20/2022
- Testimonials & Endorsements Under the SEC's New Marketing Rule - 9/29/2022
- How to Develop Compliance Training & Complying with the New IAR CE Rule - 7/21/2022
- Reviewing & Updating Form U4 & Form ADV Part 2B - 6/23/2022
- Updating Form ADV - 5/26/2022
- Reviewing and Updating Investment Adviser Client Agreements - 4/27/2022
- 2022 Exam Priorities - 3/31/2022
- IRA Rollover Compliance - 2/24/2022
- Compliance Roundtable with RCC Consultants - A 2021 Year End Review - 12/15/2021
- Form ADV Part 3 Guidance - 11/18/2021
- IRA Rollovers Under U.S. Department of Labor's PTE 2020-02 - 10/28/2021
- Compliance Concerns with Wrap-Fee Accounts - 9/30/2021
- RIA Website Accessibility - 7/22/2021
- SEC's New Marketing Rule - Session 4 - Client Testimonials - 6/24/2021
- SEC's New Marketing Rule - Session 3 - Updating Solicitor Arrangements - 5/26/2021
- Licensing IARs Under New York's New Requirements - 4/22/2021
- 2021 SEC Exam Priorities - 3/4/2021
- SEC's New Marketing Rule - Session 2 - Solicitors & Testimonials - 2/4/2021
- How to Become a Registered Investment Adviser - 1/29/2021
- SEC's New Marketing Rule - Session 1 - Advertising - 1/28/2021
- Preparing a Compliance Calendar for 2021 - 12/16/2020
- Best Practices to Reduce the Risks of Arbitration and Litigation - 10/22/2020
- Compliance Concerns with Private Funds - 9/24/2020
- Bringing On Investment Adviser Reps - 7/23/2020
- Compliance with Form ADV Part 3 Requirements - 6/24/2020
- Compliance Tips for Covid-19 and Volatile Markets - 3/26/2020
- Common Questions For RCC Consultants - 2/20/2020
- How to Report Elder Abuse to Adult Protective Services - 1/22/2020
- 2020 SEC Exam Priorities for Investment Advisers - 1/16/2020
- Compliance Talk with RCC Consultants – A 2019 Year End Review - 12/11/2019
- Investment Adviser Fiduciary Duty - 11/14/2019
- Tips for Preparing Your Form ADV Annual Amendments - 10/17/2019
- Why Investment Advisers Should Carry E&O and Cybersecurity Insurance - 8/22/2019
- Performance Advertising for Investment Advisers - 7/25/2019
- How the SEC's Recent Approval of Form CRS/ADV Part 3 Affects Investment Advisers - 6/20/2019
- Cybersecurity: Could Your Investment Adviser Pass Regulatory Scrutiny - 5/16/2019
- Compliance Talk with RCC Consultants - RIA Fee Billing Practices - 4/18/2019
- How an Investment Adviser Can Create and Maintain a Strong Culture of Compliance - 3/21/2019
- How to Become a Registered Investment Adviser - 3/13/2019
- Form ADV Amendments - Once a Year May not be Enough - 2/21/2019
- SEC 2019 Exam Priorities for RIAs and Tips for Making Sure You're Prepared - 1/24/2019
- Compliance Talk with RCC Consultants - A Year End Review - 12/12/2018
- Succession Planning for Investment Advisers - Why? & How? - 11/15/2018
- Identifying, Disclosing and Mitigating Conflicts of Interest - 10/18/2018
- Conducting and Documenting an Annual Review of RIA Policies and Procedures - 9/20/2018
- Compliance Concerns for Investment Advisers Working with Senior Investors and Vulnerable Clients - 7/19/2018
- Investment Advisory Fees and Other Expenses - 6/21/2018
- Highlights from the April 2018 SEC Compliance Outreach Program National Seminar - 5/23/2018
- Common Investment Adviser Books and Records Deficiencies - 4/26/2018
- Compliance Requirements for Investment Adviser Advertising - 3/22/2018
- SEC Exam Priorities and Exam Readiness 2018 - 2/22/2018
- Planning Your Investment Adviser Compliance Program for 2018 - 1/25/2018
- What We Learned From Investment Adviser Regulatory Compliance Exams in 2017 - 12/14/2017
- Compliance Update on Investment Adviser's Use of Social Media - 11/30/2017
- Custody Rule Implications for Investment Advisors: First- Party vs. Third-Party Transfers - 10/26/2017
- Preparing Form ADV Annual Amendments - 9/7/2017
- Highlights from the June 2017 SEC Compliance Outreach Program Regional Seminar - 7/27/2017
- Applicability Dates of Best Interest Contract Exemption under DoL's Fiduciary Rule - 6/21/2017
- Developing and Maintaining Customized Written Compliance Policies and Procedures - 5/18/2017
- Understanding the Role of the Chief Compliance Officer - 4/27/2017
- SEC Exam Priorities and Common Exam Deficiencies - 3/23/2017
- Post DoL Rule – RIA Requirements for Addressing Conflicts of Interest - 2/7/2017
- Preparing Your Form ADV Annual Amendment 2017 - 1/26/2017
- Strategies for Registered Investment Advisers to Comply with the DoL New Conflicts of Interest Rule - 11/10/2016
- Investment Adviser Branch Office Supervision & Supervision of IARs with Past Disciplinary Histories - 10/20/2016
- Investment Adviser Custody Requirements – Could Your Firm Have Custody and Not Know It? - 9/29/2016
- DoL New Conflict of Interest Rules-Implications for RIA Only Firms - 8/11/2016
- Investment Adviser Compliance for RIAs with Representatives Dually Licensed with a Broker-Dealer - 7/21/2016
- Assessing Your Investment Adviser’s Compliance Culture - 6/23/2016
- Preparing for a Regulatory Exam - 5/19/2016
- Investment Adviser Books and Records Requirements - 4/28/2016
- Annual Compliance Review Recordkeeping and RIA Express – Compliance Review Demonstration - 3/24/2016
- Conducting an Annual Compliance Review – Session 13 – Client Documents, Proxy Voting, Foreign Clients, ERISA - 2/25/2016
- Conducting an Annual Compliance Review – Session 12 – Complaints, Regulatory Exams, Regulatory Investigations, Whistleblowers - 1/21/2016
- Conducting an Annual Compliance Review – Session 11 – Trading Records, Portfolio Management Records, Financial Planning - 12/17/2015
- Conducting an Annual Compliance Review – Session 10 – Business Continuity Plans & Information Security - 11/19/2015
- Conducting an Annual Compliance Review – Session 9 – Fees & Custody, Form 13F Filings, Private Funds - 10/22/2015
- Conducting an Annual Compliance Review – Session 8 – Organized and Operational Records - 9/24/2015
- Conducting an Annual Compliance Review – Session 7 – Electronic Communications, Electronic Storage, Privacy Records - 8/20/2015
- Conducting an Annual Compliance Review – Session 6 – Utilizing Solicitors, Serving as a Solicitor, and Service Providers - 7/23/2015
- Conducting an Annual Compliance Review – Session 5 – Advertising and Social Media - 6/25/2015
- Conducting an Annual Compliance Review – Session 4 – Supervision, Branch Offices, Outside Business Activities - 5/14/2015
- Conducting an Annual Compliance Review – Session 3 – Code of Ethics - 4/30/2015
- Conducting an Annual Compliance Review – Session 2 – Registration - 3/26/2015
- Conducting an Annual Compliance Review – Session 1 - 2/26/2015
- Insight into SEC Exam Priorities for 2015 - 2/12/2015
- Preparing Your Form ADV Annual Amendment - 1/22/2015
- Preparing Your Compliance Calendar for 2015 - 11/20/2014
- Cybersecurity for Investment Advisers - 10/30/2014
- Building a Strong Compliance Culture for Your Investment Adviser - 9/25/2014
- Compliance for Independent Registered Investment Advisers with Representatives Also Registered with a Broker-Dealer - 8/21/2014
- Investment Adviser Service Provider Due Diligence Reviews - 7/24/2014
- Compliance Requirements for Investment Adviser Advertising and Marketing - 6/19/2014
- Establishing and Supervising Solicitor Arrangements - 5/15/2014
- Investment Adviser Code of Ethics Requirements - 3/20/2014
- Preparing for a Regulatory Exam - 2/20/2014
- Preparing Your Form ADV Annual Amendment - 1/16/2014
- Preparing Your Compliance Calendar for 2014 - 12/12/2013
- Conducting an Annual Compliance Review - 11/14/2013
- Identity Theft & Third-Party Wire & Check Fraud - 10/17/2013
- Developing and Implementing an Effective Customized Compliance Program - 10/3/2013
- Investment Adviser Books and Records Requirements - 9/19/2013
- Custody Implication for Investment Advisers - 8/15/2013
- Conducting a Risk Assessment/Risk Inventory - 7/25/2013
- Social Media and Email Compliance for Investment Advisers - 6/20/2013
- Key Elements that Should be Included in an Investment Advisory Client Contract – Presented by Bryan Hill Law - 6/6/2013
- Understading the New Identity Theft Red Flags Rules and How SEC Registered Investment Advisers are Affected - 5/9/2013
- Understanding the New Identity Theft Red Flags Rules and How SEC Registered Investment Advisers are Affected - 5/9/2013
- Learning from Other's Mistakes - 4/18/2013
- Getting Your Compliance Calendar Ready for 2013 - 12/6/2012
- Establishing Information Security Programs for Registered Investment Advisers - 9/13/2012
- Solutions and Answers to Form U4 and Form U5 Challenges - 8/23/2012
- New 408(b)(2) Disclosure Requirements Affect Investment Advisers to ERISA Plan Accounts - 5/10/2012
- Maintaining Investment Advisor Books & Records - 4/12/2012
- SEC Requirements for Performance Advertising - 3/15/2012
- Professional Ethics for Investment Adviser Representatives - 2/9/2012
- Understanding and Preparing for the 'Switch' for Mid-Sized Advisors - 12/15/2011
- Getting Your Compliance Calendar Ready for 2012 - 12/8/2011
- 2011 Review – Are You Aware of the Changes in 2011 and Is Your Investment Advisor On Track for 2012? - 11/11/2011
- Compliance for Social Media - 10/13/2011
- Basic Training for a CCO - 8/18/2011
- My New ADV Part 2 Is Filed - Now What? - 4/19/2011
- Making Compliance Resolutions for 2011 - 12/2/2010
- Understanding the New ADV Part 2 - 10/21/2010
- Maintaining Required Books and Records - 7/28/2010
- Addressing Outside Business Activities & Conflicts of Interest - 6/24/2010
- Updating Written Compliance Policies and Procedures - 5/12/2011
- Beyond Privacy Notice – Safeguarding Client Data - 4/15/2010
- Impact of New Custody Rule on an RIA Operating a B-D, Qualified Custodian or Private Fund - 3/25/2010
- Exploring the SEC's New Custody Rule - 2/25/2010
- Preparing for an SEC Exam - 2/11/2010
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Regulatory Exams
- SEC Exam Information Request List - Denver Region - May 2021
- SEC Exam Request List - Denver Region - June 2020
- State of Washington - IA Document Request List - 1.2022
- State of Indiana Securities Division - Examination - March 2021
- SEC Examination Request List - February 2021
- State of Washington Department of Financial Institutions - Division of Securities - Document Request List - November 2020
- SEC Exam Request List - Washington DC Region - October 2020
- Utah Securities Division - Letter of Caution - AR Licensing of Owners - May 2020
- SEC Exam - Denver - December 2019
- SEC Exam - LA - Information Request List - October 2019
- Examination - Arkansas Securities Department - First Document Request List - October 2019
- Examination of Books & Records - Tennessee Department of Commerce & Insurance - September 2019
- Exam - State of Missouri - August 2019
- SEC Exam - Miami Division - Initial Exam Request Letter - August 2019
- SEC Exam Letter - Examination of Compliance - August 2019
- SEC Exam - Request List - August 2019
- Colorado - Exam Letter - June 2019
- SEC Exam - Deficiency Letter - June 2019
- Regulatory Guidance - Pennsylvania Bureau of Securities Compliance & Examination Guidance on Custody for Investment Advisers with SLOA - June 2019
- Exam - Tennessee Information Request Letter - May 2019
- Colorado Exam Priorities - May 2019
- SEC Exam - Colorado Information Request Letter - May 2019
- Exam - Pennsylvania Self Inspection Checklist - 2015
- Exam - Nebraska - Routine Exam - Deficiency Letter - March 2019
- Exam - Nebraska - Onsite Routine Exam - F/U Findings Letter by Regulator - Financial Statement (Collected but Unearned Income) and Client Consent for Assignment - December 2018
- SEC Exam - Inadvertent Custody Issue Findings - December 2018
- Exam - SEC/San Francisco Region - New Registration - Adviser to Private Fund
- Exam - California - Written Online Investment Adviser Examination - 2018
- Exam - Tennessee - Info Request List & Pre-Exam Questionnaire - October 2018
- SEC Exam - Log of Requested Docs & Info - October 2018
- Indiana Securities Division - 3rd Party SLOA Custody Compliance Alert - October 2018
- Exam - Pennsylvania - Routine Exam - Info Request List - August 2018
- Exam - SEC - Denver - New Investment Adviser Exam - Info Request List - July 2018
- Exam - SEC - Info Request List - Wrap Fee Program, Portfolio Management, Trade Execution and Financials - January 2018
- Exam - SEC - Info Request List - New Investment Adviser Transitioning from State to SEC - April 2018
- Exam - SEC - Info Request List - Fee Audit & Crypto-Currency
- Exam - Colorado - Routine Exam - Info Request List - April 2018
- Exam - Oklahoma - Routine Exam - Info Request List - Custodians, WSP, Privacy, Financials, Employees, Private Funds & Solicitors
- Investment Adviser Self-Inspection Checklist - Virginia - Registration, Form ADV Disclosures, Supervision, Required Record Keeping, Custody - 2013
- Colorado Securities Division - Sample Guidance for Ongoing Financial Planning - November 22, 2022
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Sample Compliance Forms
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- Advertising – Assignment/Buy-Sell/Succession
- Advertising – Book Disclosures
- Advertising – Business Card Checklist & Footers for Emails and Letterhead/Stationery
- Advertising – Case Studies – Guiding Principles
- Advertising – Checklist for Common Compliance Issues with Non-Performance Advertising
- Advertising – Compliance Review Spreadsheet
- Advertising – D/B/A Name Guidance
- Advertising – Professional Designation Reporting Form
- Advertising – Radio, Podcast & Broadcast Over Social Media – Best Practices
- Advertising – Report Showing Past Performance of Recommended Funds – Disclosure
- Advertising – Seminar Presentation Disclosures
- Advertising – Social Media Review-Approval Form
- Advertising – Social Media/Email – Dirty Word List for Surveillance
- Advertising – Strategy Fact Sheet – Disclosures
- Advertising – Website Terms, Conditions & Disclosures
- Advertising/Marketing Review Form
- Advertising - Accessibility - Best Practices Checklist
- Advertising - Endorser (Unaffiliated) - Disclosure Statement
- Advertising - Testimonial/Endorsement (No Compensation) Authorization
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- Assignment/Change of Ownership - Client Letter - Confirmation of New Owner After 60 Day Notice with 45 Day Rescission - No Response
- Assignment/Change of Ownership – Client Letter – Rep Starting New Firm, Dual IAR Registration During Transition, 60 Days’ Notice and Authorization to Release Client Information
- Assignment - Name Change Only - Letter to Client
- Client Letter - Assignment/Change of Ownership - Confirmation of New Owner After 60 Day Notice
- Client Letter - Assignment/Change of Ownership – Assignment of Client Agreement to New Firm (Started by Reps at Old Firm) – No Response
- Client Letter - Assignment/Change of Ownership – Change of Controlling Ownership – Client Written Response Required
- Client Letter - Assignment/Change of Ownership – Confirmation of Assignment of Advisory Agreement after Initial 60 Day Notice
- Client Letter - Assignment/Change of Ownership – Death of Former Owner – New Owner – No Response Consent
- Client Letter - Assignment/Change of Ownership – Internal Sale – 60 Day Notice – No Response Consent
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- Bank – Advertising & Communication Checklist
- Bank – Client Acknowledgement – RIA Not Bank & Investments Not Insured
- Bank – Referral Arrangement Disclosure Statement to Client
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- Books & Records – Checks Received & Checks Forwarded Log
- Books & Records – Client File Review Form
- Books & Records – Trade Blotter for Investment Advisers
- Books & Records – Documentation Log and Suggested List of Compliance Files and Reports
- Books & Records – Client Meeting Notes & Checklist
- Books & Records – Document Retention Spreadsheet
- Foreign Investment Adviser – Undertaking to Provide Books & Records to SEC
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- Assignment - Name Change Only - Letter to Client
- Client Complaint – Acknowledgement of Receipt
- Client Letter - ADV-W – Notification of Firm's ADV-W
- Client Letter - Assignment/Change of Ownership - Confirmation of New Owner After 60 Day Notice
- Client Term – Client Letter – Notifying Termination of Services & Waiver of Notice Period
- Client Letter - Assignment/Change of Ownership – Assignment of Client Agreement to New Firm (Started by Reps at Old Firm) – No Response
- Client Letter - Assignment/Change of Ownership – Change of Controlling Ownership – Client Written Response Required
- Client Letter - Assignment/Change of Ownership – Confirmation of Assignment of Advisory Agreement after Initial 60 Day Notice
- Client Letter - Assignment/Change of Ownership – Death of Former Owner – New Owner – No Response Consent
- Client Letter - Assignment/Change of Ownership – Internal Sale – 60 Day Notice – No Response Consent
- Rep Term – Client Letter – Confirming Rep Term & Release of Info to New Firm
- Rep Term – Client Letter – Existing Rep Termination & New Successor Rep
- Rep Term – Client Letter – Rep Starting New Firm, Temporary Dual Registration, No-Response Notice
- Suitability – Client Letter – Confirming Accounts & Objectives
- Fee - Client Letter – New Procedure – 12 Month Look for Back for Valuing Private Investment Funds
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- Conflicts of Interest – Log
- Conflicts of Interest – Checklist
- Conflict of Interest – Financial Planning – Recommending Products with Varying Commissions
- Conflict of Interest - Financial Planning – Varying Compensation for Insurance/Securities – Client Acknowledgement
- Conflict of Interest - Cash Sweep Program
- Conflicts of Interest – Fixed Indexed Annuities – Best Practices
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- Custody – Credit Card/ACH Payments – Best Practices for Avoiding Custody
- Custody – SLOA for First-Party Transfers – Spreadsheet for Documenting Requirements
- Custody – Spreadsheet for Reviewing Qualified Custodian’s Account Documentation for Inadvertent Custody
- Custody – SLOA Transfer to 3rd Party – Spreadsheet Documenting Requirements
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- Cybersecurity - Best Practices Checklist
- Cybersecurity - Best Practices for Avoiding and Responding to Phishing Attacks
- Cybersecurity - Best Practices for RIA Collecting Devices for Digital Forensic Expert
- Cybersecurity - Training to Avoid Phishing
- Cybersecurity – 12 Steps for an RIA to Improve Security of Client Information
- Cybersecurity – Best Practices Checklist
- Cybersecurity – Cleaning Company Acknowledgement – Background Checks
- Cybersecurity – Conducting Due Diligence of Cloud Computing Service Providers
- Cybersecurity – Employee Acknowledgement
- Cybersecurity – GDPR Best Practices Checklist for Website
- Cybersecurity – Phishing Email – Letter Notifying Client
- Cybersecurity – Website Security Checklist for an Investment Adviser
- Cybersecurity Package
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- Due Diligence - Vendor Due Diligence Checklist
- Due Diligence – Alternative Investment – Review Form
- Due Diligence – Client Acknowledgement – No Due Diligence of Service Provider Selected by Client
- Due Diligence – Reimbursement of 3rd Party Professional Services – Client Acknowledgement
- Due Diligence (Ongoing) Questionnaire for Signal/Model Provider's Compliance Program
- Due Diligence (Ongoing) Questionnaire for Sub-Adviser's Compliance Program
- Due Diligence (Ongoing) Questionnaire for Third-Party Money Manager Compliance Program
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- Form ADV - Language - COVID-19 Risks
- Form ADV - Language - IAR PPP Loan Disclosure
- Form ADV - Part 3 - Conversation Starters Script
- Form ADV - Part 3 - Cover Letters for Relationship Summary
- Form ADV – Annual Offer Letter
- Form ADV – Language – Item 18.B – PPP Loan
- Form ADV – Request/Receipt Log
- Form ADV – Revisions Log
- Form ADV – Sample Language – Rollover Recommendation
- Form ADV – Worksheet for Calculating Regulatory Assets Under Management
- Form ADV – Worksheet for Calculating Regulatory Assets Under Management
- Form ADV Part 3 - Training Tool
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- Invoice – Hourly
- Invoice – Asset Management Services (Asset Based Fee)
- Invoice - Retainer Request
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- Outside Business Activity – Acknowledgement that Rep’s Non-Profit Board of Director’s Activity Is Outside of RIA
- Outside Business Activity – Client Acknowledgement - General
- Outside Business Activity – Client Acknowledgement that Fixed Indexed Annuity Recommendation Is an Outside Activity
- Outside Business Activity – Client Acknowledgement that Rep’s Trustee Services Are Outside of Investment Adviser Firm
- Outside Business Activity – Investigation Checklist
- Outside Business Activity – Recommending FIA in lieu of SMA in Retirement Account – Client Acknowledgement
- Outside Business Activity – Reporting Form
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- Privacy – Client Authorization for 3rd Party to Release Confidential Info. to Investment Advisor
- Privacy – Client Authorization to Release Copy of Client Records to Departing Representative
- Privacy – Client Privacy Policy Notice (Sample)
- Privacy – Client Privacy Policy Notice Request/Receipt Log
- Privacy – Confirmation that Client Provided Rep with Info to Establish New Account
- Privacy – Permission to Disclose Personal Info on Behalf of Client
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- Suitability – Private Equity Risk Disclosure
- Private Equity - Compliance Checklist for Investment Adviser When Recommending PE Investment
- Private Equity Risk Disclosure
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- Personal Securities Transactions - Brokerage Account Disclosure Form
- Personal Securities Transactions – Annual/Initial Personal Securities Holding Report
- Personal Securities Transactions – Letter to Request Duplicate Confirmations & Statements
- Personal Securities Transactions – Pre-Clearance Form
- Personal Securities Transactions – Quarterly Personal Securities Transaction Report
- Personal Securities Transactions – Supervising for Insider Trading Checklist
- Personal Securities Transactions Form: Personal Securities Transactions – Personal Securities Trading Request Form
- Personal Securities Transactions - Checklist for Reviewing PSTs
- PST - Checklist for Personal Account Not Controlled by Access Person
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- Rep - Recruiting - New Firm Recommending Prospect Retain Attorney Before Affiliating
- Rep - Recruiting - Best Practices Checklist
- Rep - Supervision - Letter of Caution
- Rep – Diminished Capacity of IAR
- Rep – Prospective Rep Checklist – Compliance Issues
- Rep – IAR Annual Questionnaire
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- Rep Term - Rep Letter - Notification of Termination
- Rep Term – Checklist
- Rep Term – Client Letter – Confirming Rep Term & Release of Info to New Firm
- Rep Term – Client Letter – Existing Rep Termination & New Successor Rep
- Rep Term – Client Letter – Rep Starting New Firm, Temporary Dual Registration, No-Response Notice
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- SEC Exam - Privilege Log
- SEC Exam – Best Practices Checklist
- SEC Exam – Investment Adviser's Confirmation of New Deadline for Response
- SEC Exam – Log of Requested Docs & Info
- SEC Exam – Mock Exam Document Request List
- SEC Exam – Response to Deficiency or Findings Letter from Securities Regulator
- SEC Exam – Sample Letters Requesting Confidential Treatment under FOIA
- Preparing for an SEC Exam
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- Senior/Vulnerable Clients – Client Authorization to Communicate with Trusted Emergency Contact
- Senior/Vulnerable Clients – Compliance Package
- Senior/Vulnerable Clients – Internal Reporting Form for Exploitation
- Senior/Vulnerable Clients – State Reporting Requirements
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- Solicitor Annual Questionnaire – Affiliated and Licensed
- Solicitor Annual Questionnaire – Affiliated and Unlicensed
- Solicitor Annual Questionnaire – Unaffiliated and Unlicensed
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- Suitability - Leveraged/Inverse ETFs - Client Acknowledgement
- Suitability – Broker-Dealer (Commission) v. RIA (Fee) Account – Client Acknowledgement
- Suitability – Client Letter – Confirming Accounts & Objectives
- Suitability – Excessive Withdrawals from a Retirement Account – Client Acknowledgement
- Suitability – Marijuana-Related Investment – Acknowledgement by Client of Speculative Nature
- Suitability – Private Equity Risk Disclosure
- Suitability – Recommending Proprietary Investment or Fund Checklist
- Suitability – Rep Did Not Solicit or Recommend Investment – Investor Acknowledgement
- Suitability – Retirement Plan Rollover – Client Acknowledgement
- Suitability – Risk Tolerance Questionnaire for Clients
- Suitability – Tax Efficiency – Client Acknowledgement – Account Not Managed for Taxes
- Suitability – Wrap vs. Non-Wrap Account – Client Acknowledgement
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- Checks Received and Forwarded Log
- Client as Investor/Owner in RIA – Checklist of Compliance Issues
- Client Authorization for Electronic Delivery of Documents
- Compliance Issues Log
- Compliance Training/Meeting Attendance Sign-in Form
- DoL Fiduciary Rule - Letter to DoL Re: Intent to Rely upon Best Interest Contract Exemption
- Non-Access Person Acknowledgement Form
- Non-Licensed Meeting Attendee – Acknowledgement
- Order Memorandum/Trade Ticket
- Retirement Plan Participant's User ID & Password – Internal Checklist for Custody
- Investment Adviser Self-Inspection Checklist - Virginia - Registration, Form ADV Disclosures, Supervision, Required Record Keeping, Custody - 2013
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Training Materials
- Senior/Vulnerable Clients - Training
- Senior/Vulnerable Clients - Training Quiz
- IAR CE - Tracking Spreadsheets
- Interactive Compliance Training Tool - Template
- Interactive Compliance Training Tool - COMPLETE with Questions
- Form ADV Part 3 - Training
- Annual Compliance Training – Case Studies – Conflicts of Interest, Social Media, Alternative Investments
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Can my firm register as an investment advisor without an individual qualified to serve as an investment advisor representative?
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