Regulation S‑P Service Provider Due Diligence & Information Security Bundle

These sample documents should be considered a starting point, and purchaser should not treat these sample documents as final documents ready for use. The sample documents have 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.

These sample documents may not be applicable or appropriate for every investment adviser. The purchaser should not consider sample documents 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.

These sample documents are 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Due to changes of investment adviser laws and rules, these sample documents may become outdated and need to be updated or discontinued. RIA Compliance Consultants, Inc. will not be providing any subsequent updates of these 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 these sample documents.

Since these sample documents 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 these documents.

These sample documents are 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 sample forms. Additionally, the purchaser understand that unless otherwise agreed to in writing, RIA Compliance Consultants, Inc. is not responsible for customizing these sample documents, updating these sample documents, 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 these sample documents nor license the use of these sample documents to a third-party.

Not Information Security Experts

RIA Compliance Consultants is not an expert in information security. Our employees are not trained or certified in information security. We do not provide information security risk assessments or audits of information security plans. RIA Compliance Consultants offers the following practices and techniques for the reader to start a discussion with his or her IT & information security staff or consultants. These practices are general in nature and may not be applicable to particular investment adviser firm’s business model or information systems. Moreover, these practices may have become dated or might be considered ineffective by the investment adviser’s IT and information security staff or consultants. As a result, this document and these practices are provided to you on “as is” basis with no warranty.

These practices have not been customized to your investment adviser’s business model, information systems, the specific investment advisory rules of your investment adviser’s securities regulator or your investment adviser’s written supervisory procedures and code of ethics. These practices may not be applicable or appropriate for your investment adviser. Likewise, there may be risks associated with these practices. You should not consider these practices as an exhaustive, comprehensive or definitive list of the items necessary to meet your investment adviser’s obligations to protect confidential client information under the applicable investment adviser laws and rules.

Since these sample documents may not reflect the specific investment advisory requirements of your securities regulator, please check with the securities regulator(s) with jurisdiction over your investment adviser before using these sample documents.Since technology and the strategies/tactics of fraudsters is likely to evolve and change, it’s likely that these practices may become less effective or fail to address certain risks over time. As a result, RIA Compliance Consultants recommends that the investment adviser firm periodically review the latest developments in cybersecurity and identity theft fraud and update its information security plan and practices.

These practices are not a substitute for retaining an information security consultant to advise and assist you regarding your investment adviser’s information security plan and practices. (RIA Compliance Consultants does not consider itself an information security consultant and does not offer risk assessments of information security plans and practices.) Additionally, you understand that unless otherwise agreed to in writing, RIA Compliance Consultants, Inc. is not responsible for customizing these practices, preparing your investment adviser’s written supervisory procedures or code of ethics, or notifying you of changes to the investment advisor laws and rules.