WSP/CoE Section Update – Reports to Parent Company Do Not Trigger Supervised Person, Access Person

$250.00

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 a supervised person or access person of the investment adviser firm.

 

An investment adviser firm should exercise caution before using this sample WSP section.  In particular, the investment adviser firm should carefully review the definitions of investment adviser representative, supervised person and access person of the applicable regulators and then thoroughly discuss/determine the role of the holding company’s president in light of such definitions.    Please understand that this is merely a sample or template written supervisory procedure/compliance manual section. It has not been customized to your investment adviser firm or your regulator’s requirements. It’s not a substitute for working with an investment adviser compliance professional.  You will need to carefully review and finalize this sample supervisory procedure/compliance manual section for your investment adviser firm before you start to utilize it.  For additional details about the limitations of this sample document, please refer to the disclosure page with the sample written supervisory procedure/compliance manual section.

 

Included with Bronze, Silver, Gold and Platinum Packages.

 

This sample written supervisory procedure/compliance manual section is delivered via the purchaser’s online subscription account with RIA Compliance Consultants.  If the purchaser does not have an online subscription account, after the purchase, the purchaser will receive a follow-up email directing the purchaser to establish online subscription account. This step will need to completed before our systems can deliver the sample document.  For an instructional video, please visit http://ria-compliance-consultants.com/subscription-account-demo/

 

Initially posted in September 2017.

SKU: CM001 Categories: , Tag:

Description

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 a supervised person or access person of the investment adviser firm.

An investment adviser firm should exercise caution before using this sample WSP section.  In particular, the investment adviser firm should carefully review the definitions of investment adviser representative, supervised person and access person of the applicable regulators and then thoroughly discuss/determine the role of the holding company’s president in light of such definitions.    Please understand that this is merely a sample or template written supervisory procedure/compliance manual section. It has not been customized to your investment adviser firm or your regulator’s requirements. It’s not a substitute for working with an investment adviser compliance professional.  You will need to carefully review and finalize this sample supervisory procedure/compliance manual section for your investment adviser firm before you start to utilize it.  For additional details about the limitations of this sample document, please refer to the disclosure page with the sample written supervisory procedure/compliance manual section.

Included with Bronze, Silver, Gold and Platinum Packages. Initially posted in September 2017.

Disclosures

This is a sample section for a compliance manual or written supervisory procedures/code of ethics (WSP/CoE) for use by your investment adviser.

This sample section 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, rules regulatory interpretations and enforcement actions, this sample section may become outdated and need to be updated or discontinued.

This sample section is not a substitute for retaining a compliance professional to advise and assist you as the purchaser regarding your investment adviser’s compliance program.

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 compliance manual section as a final document ready for use.  The sample compliance manual 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.

Unless otherwise agreed to in writing, you understand that RIA Compliance Consultants, Inc. is not responsible for customizing this sample section, implementing the use of this sample section, updating this sample section, otherwise preparing your investment adviser’s written supervisory procedures or code of ethics, or notifying you of changes to the investment advisor laws and rules.

This sample compliance manual may not be applicable or appropriate for every investment adviser. The purchaser should not consider a sample compliance manual section purchased from our online store as an exhaustive, comprehensive or definitive analysis or list of the items necessary to meet the purchaser’s obligations under the applicable investment adviser laws and rules.

This sample compliance manual section 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 compliance manual section may become outdated and need to be updated or discontinued.  RIA Compliance Consultants, Inc. will not be providing any subsequent updates of this sample compliance manual section 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 compliance manual section.

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 sample compliance manual section.

This sample compliance manual section 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 compliance manual section, updating the sample compliance manual section, preparing the purchaser’s compliance manual, 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.

Reviews

There are no reviews yet.

Only logged in customers who have purchased this product may leave a review.