February 19, 2017

Investment Advisers

The cost of your firm’s Compliance, Legal, Operations, and Sales personnel and attendant technology and outside vendor support, depending upon the size of your registered investment adviser and the number of IARs and support staff you have, can be extremely high.

The SEC-FINRA COMPLIANCE Consulting Group can assist you in managing those costs effectively and efficiently while helping you to meet and satisfy the compliance and risk management responsibilities and requirements.  Here are some of the types of products and services we offer:

GENERAL TYPES OF INVESTMENT ADVISER PRODUCTS AND SERVICES:

  • Formation and Registration of Investment Advisers
  • General and Customized Compliance Support
  • Focus on Small and Mid-size Investment Advisers
  • Keeping management abreast of the changing regulatory environment and providing interpretative assistance
  • Interface with Federal and state regulators
  • Federal and State Registration and Licensing
  • General Litigation*
  • Wells Notice Representation*
  • Representation in SEC and State Regulatory Investigations*
  • Securities Employee Regulatory Representation*
  • Compliance Program Design and Implementation
  • Development and Drafting of Policies and Procedures
  • Compliance Program Review and Testing
  • Conduct Annual Reviews pursuant to Rule 206(4)-7 under the Investment Advisers Act of 1940
  • Operational and Regulatory Risk Analysis
  • Designing, Implementing, and Conducting a relevant Examination Program
  • Conducting mock SEC as well as branch office examinations
  • Preparation for upcoming SEC examinations and assistance in responding to examination findings
  • Assistance in the review of and responses to customer complaints
  • Conducting Solicitation and Marketing Program Review
  • Developing and updating Business Continuity Plans and Succession Planning strategies
  • Review and evaluate the firm’s cybersecurity program and procedures, provide training for employees, and test and verify the firm’s cybersecurity protection and preparedness
  • Conduct Due Diligence and provide support for Mergers and Acquisitions
  • Business Restructuring & Chapter 11 Bankruptcy Protection*

* Legal services provided through participating and member Law Firms

SPECIFIC TYPES OF INVESTMENT ADVISER PRODUCTS AND SERVICES:

General and Customized Compliance Support

  • Analyze the unique needs of individual and small firm advisers and tailor a compliance program to meet those needs
  • Review and provide reports of relevant rulemaking and enforcement activity
  • Analyze regulatory and industry developments, including emerging best practices
  • Provide ongoing, real-time support for the firm’s staff
  • Conduct and document staff training
  • Coordinate and oversee supplemental temporary staffing to address special situations, e.g. regulatory inspections
  • Provide independent review and support of the Chief Compliance Officer’s performance

Focus on Small Firm Investment Advisers

  • Analyze the unique needs of individual and small firm registered investment advisers and investment adviser representatives and tailor a compliance program and business plan to meet their needs

Federal and State Registration and Licensing

  • Prepare draft of all registration materials for client review
  • Conduct or oversee client conduct of online and other registration processes
  • Conduct or oversee annual and special updating of registration processes

Compliance Program Design and Implementation

  • Develop a blueprint to address identified areas of operational and regulatory risk
  • Develop a program to assist client staff to recognize changes in firm business or business practices that have operational risk and regulatory aspects
  • Assist client staff with ongoing updates and modifications of program design

Development and Drafting of Policies and Procedures

  • Prepare a comprehensive set of both policies and implementing procedures tailored to the client firm that fulfill the mandates of the compliance plan blueprint
  • Prepare a comprehensive set of policies and procedures to assist the Chief Compliance Officer in the conduct of his/her oversight responsibilities
  • Prepare a comprehensive set of internal control points for firm management to permit assessment of the compliance program generally and the Chief Compliance Officer specifically

Compliance Program Review and Testing

  • Conduct independent “mock audit” of client compliance program
  • Assist Chief Compliance Officer in conducting Rule 206 (4)-7 annual reviews
  • Review and evaluate the firm’s cybersecurity program and procedures, provide training for employees, and test and verify the firm’s cybersecurity protection and preparedness

Operational and Regulatory Risk Analysis

  • Inventory areas of client operational and regulatory risk
  • Analyze and prioritize identified areas of operational and regulatory risk
  • Perform annual review of client business to update and revise inventory, analysis and prioritization of operational and regulatory risk

Designing, Implementing, and Conducting an applicable and relevant Examination Program

  • Develop customized Examination Modules
  • Conduct on-site and remote home office and branch office examinations
  • Perform mock regulatory exams

Solicitation and Marketing Program Review

  • Analyze client internal and external marketing, sales and capital introduction programs
  • Review performance presentation information
  • Review solicitation, marketing and client reporting materials
  • Assist and review responses to Requests for Proposals and Due Diligence Questionnaires

Mergers and Acquisitions Support

  • Conduct due diligence review of operational and regulatory risk procedures of acquisition candidates
  • Develop a plan for a post-acquisition compliance program
  • Assist in implementation of post-acquisition compliance program

The SEC-FINRA COMPLIANCE Consulting Group has offices in the New York metropolitan area and Florida and Consultants located throughout the United States.  For more information on how we can be of assistance to you and your firm, please contact us today, either by telephone (800-SEC-9906) or email, for a free consultation.