Pursuant to Section 206 of the Investment Advisers Act of 1940, an investment adviser has a duty to its clients to conduct a reasonable investigation concerning any third parties that provide services to the investment adviser, including cloud computing service providers. To comply with this duty, an investment adviser needs to implement a system to conduct a due diligence review of any cloud computing service provider hired by the investment adviser. These procedures should be reasonably designed to ensure that each cloud computing service provider is properly investigated before an agreement is signed with the third party.
This Sample Form is designed to help you investment adviser firm ask appropriate questions for Cybersecurity service providers.
This sample form should be considered as a starting point; the investment adviser firm will need to customize this sample form to its business model and policies and procedures.
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This sample document is merely an example for general reference and educational purposes. RIA Compliance Consultants, Inc. is providing this sample document to the purchaser on an “as is” basis with no warranty or guaranty whatsoever.
This sample document should be considered a starting point, and purchaser should not treat this sample document as a final document ready for use. The sample document has not been customized to the purchaser’s business model, the specific investment advisory rules applicable to the purchaser’s investment adviser or the written supervisory procedures and code of ethics of purchaser’s investment adviser.
This sample document may not be applicable or appropriate for every investment adviser. The purchaser should not consider a sample document purchased from our online store as an exhaustive, comprehensive or definitive list of the items necessary to meet the purchaser’s obligations under the applicable investment adviser laws and rules.
This sample document is not intended to detect or prevent fraud, selling away, Ponzi schemes, undisclosed outside business activities, inaccurate or false fee calculations, theft, misappropriation or unlawful conversion of client funds.
Due to changes of investment adviser laws and rules, this sample documented may become outdated and need to be updated or discontinued. RIA Compliance Consultants, Inc. will not be providing any subsequent updates of this sample documents to the purchaser. Likewise, RIA Compliance Consultants, Inc. will not be monitoring and reporting to the purchaser any issues related to the use of this sample document.
Since this sample document may not reflect the specific investment advisory requirements of the purchaser’s securities regulator, the purchaser should check with the securities regulator(s) with jurisdiction over its investment adviser or review any applicable rules before using this document.
This sample document is not a substitute for retaining a compliance professional to advise and assist the purchaser regarding its investment adviser’s compliance program. Unless otherwise agreed to in writing, the purchaser understands that the purchaser has not engaged RIA Compliance Consultants, Inc. in a consulting relationship by merely purchasing or utilizing a sample form. Additionally, the purchaser understand that unless otherwise agreed to in writing, RIA Compliance Consultants, Inc. is not responsible for customizing this sample document, updating the sample document, preparing the purchaser’s written supervisory procedures or code of ethics, or notifying the purchaser of changes to the investment adviser laws and rules.
Purchaser is not authorized to re-sell this sample document nor license the use of this sample document to a third-party.
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