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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?

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Off-the-shelf investment adviser compliance manuals are an excellent starting point for a registered investment adviser. However, a registered investment adviser cannot expect to just purchase an off-the-shelf compliance manual and assume that the investment adviser now has sufficient written supervisory and compliance policies and procedures for the investment adviser. These documents are typically written at a very high level to cover many areas that the typical or average investment adviser must consider when developing its own manual customized to its unique business model and circumstances. For a registered investment adviser that is utilizing an off-the-shelf compliance manual, it is imperative that the investment adviser thoroughly review all of the content of the off-the-shelf version of the compliance manual and then revise the compliance manual so that it reflects the actual operation of the investment adviser and meets any unique rules or regulations of the applicable securities regulator(s).

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