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WSP/CoE Section Update – IAR CE

May 19, 2022

This WSP/CoE Section – IAR CE is a sample investment adviser compliance manual section related to the investment adviser representative continuing education (“IAR CE”) requirements of certain state securities regulators.

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Wrap v. Non-Wrap Account

January 27, 2022

This sample written supervisory procedure/compliance manual section is intended to address the conflict of interest associated with an investment adviser which offers both wrap and non-wrap fee accounts to its investment advisory clients.

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Text Messaging Prohibited

January 27, 2022

This sample WSP section is intended for an investment adviser firm which prohibits the use of text messages between clients and supervised persons.

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Text Messaging Permitted

January 27, 2022

This sample WSP section is intended for an investment adviser firm that intends to permit its investment adviser representatives to communicate with client via text messaging.

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Succession Plan

January 27, 2022

This sample written supervisory procedure/compliance manual section for an investment adviser firm is intended to describe the succession of ownership of the investment adviser firm and/or continuation of service of its clients if the owner of the investment adviser firm dies.

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Section 13 Filings

January 27, 2022

This sample WSP/compliance manual section for an investment adviser firm describes the various Section 13 filings under the Securities Exchange Act of 1934 and outlines the procedures for filing the Form 13F and Form 13H.

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Reports to Parent Company’s President Do Not Trigger Supervised Person nor IAR

January 27, 2022

This sample written supervisory procedure/compliance manual section for an investment adviser firm is intended for an investment adviser firm owned by a holding company where the president of such holding company is not involved in the management of the investment adviser firm and thus is not licensed as an investment adviser representative nor treated as […]

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Recommending FIA in lieu of SMA Retirement Account

January 27, 2022

This sample WSP section is intended for an investment adviser firm which has investment adviser representatives that may recommend that a client invest a retirement account in a fixed indexed annuity in lieu of a separately managed account by an investment adviser. The purchaser of this sample WSP section will need to customize and/or add […]

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Protecting Older and Vulnerable Clients with Diminished Capacity

January 27, 2022

This sample WSP section entitled “Protecting Older and Vulnerable Clients with Diminished Capacity” provides examples of warning signs of financial exploitation of senior clients and examples of trusted contact and reporting procedures of suspected or possible financial exploitation. Includes updates based upon the Senior Safe Act.

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Participation on Investors Committee by Supervised Person

January 27, 2022

This sample written supervisory procedure/compliance manual section for an investment adviser firm which has a supervised person who may participate as a member of an investors committee of a private investment fund not managed or advised by or otherwise affiliated with the investment adviser firm.

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