Services

Services range from addressing a one-time, specific compliance issue to a comprehensive assessment, proposal, and implementation of an entire compliance program.

Solutions for Investment Advisers
SEC Audit Findings – Review written report from SEC and assist in drafting a response; assist in the correction of written procedures, improvement of documentation and the creation and implementation of office procedures to address the issues cited by the SEC.

Written Policy and Procedures -  Review and assess existing compliance manual procedures and if necessary make recommendations for revisions and amend the written procedures; monitor changes in regulatory policy that dictate additions, deletions or revisions of firm written procedures.

Development or Restructure of Compliance Programs – Devise a program for new Advisers or review their existing compliance program.  Recommend changes across entire program in such areas as supervisory structure, written policies and procedures, documentation creation and storage and correct any areas missing documentation or analysis.  Assist in the implementation of firm procedures to administer the compliance program and develop a system to administer the compliance program on an ongoing basis, ideally with reallocation of internal resources as available.

Organizational Structure – Review the organizational structure and educate clients on how their structure impacts the administration of the Adviser’s compliance program.  Review lines of supervision between institutional entities for effectiveness and compliance with regulatory rules and policies.

Supervisory Structure – Review existing structure to determine if reporting lines are complete and effectively supervise registered and non-registered personnel.  Correct any structures that allow for self-supervision.  Assure that the supervisory structure is properly documented in the Adviser’s files.

Code of Ethics – Create and install the Code of Ethics or review existing Code of Ethics for adequacy, completeness and documentation.  Review the implementation of the Code to assess that the procedures are being followed, that the activity is supervised and that the documentation in complete and accurate.

Sarbanes-Oxley (SBUX) Compliance – Determine how SBUX applies to the firm; review the written procedures, documentation and the implementation of the procedures in throughout the firm to evaluate and as necessary make recommendations to enhance compliance with the Sarbanes Oxley legislation.

State or SEC Registration – Assist entities in the creations of the ADV’s and various other disclosure/submission documentation and account establishment with the IARD; submit the documentation to the SEC in order to register as an investment adviser.  Advise management on  the key aspects of establishing an effective compliance program once registration becomes effective.

Compliance Personnel Training – Provide a review of regulatory and Firm policies and procedures to educate new personnel on the compliance program.  Train personnel on effective methods or procedures to effectively administer a compliance program.  Educate and detail the importance of documentation and provide training and assistance on fully documenting the Adviser’s compliance program.

Bridge Transitions for CCO or Other Compliance Positions – Assist the firm in the administration, application and documentation of the compliance program while a change in personnel is in progress to assure that compliance and supervisory processes are not temporarily interrupted as new personnel acclimate to the firm.

Business Continuity Plans – Assist firm in the drafting a complete disaster recovery plan that addresses all key areas including an annual review, testing procedures and the training of employees on all aspects of the plan for disaster recovery.  Assure that the Adviser’s disclosure and notifications regarding the Plan are complete and accurate.

Compliance Issues for New Products – Review new products for management and provide detailed needs for written procedures, supervisory obligations, necessary documentation and an assessment of the added compliance and operational risks introduced by adding the product. 

Fiduciary Class Action Research and Claim Processing – Assure that the Firm is in compliance with its Fiduciary responsibility to clients/investors by holding their interests first and seeking the best possible outcome.  This in part is accomplished by an examination of the current and historical portfolio holdings to determine if there is a class action suit pending and if the position and time period held merits a valid claim.  If so, file all necessary documents to establish Adviser as a claimant and follow the proceedings to the point of claim payment.

Solutions for Broker Dealers
NASD Audit Findings - Review Exit Interview from FINRA and assist in drafting a response; assist in the correction of written procedures, improvement of documentation and the creation and implementation of office procedures to address the issues cited by FINRA.

Written Policy and Procedures and GAP Analysis - Review and assess existing compliance manual procedures and if necessary make recommendations for revisions and amend the written procedures; monitor changes in regulatory policy that dictate additions, deletions or revisions of firm written procedures.  Perform annual GAP analysis to support the 3013 CEO Certification of the Firm’s Compliance Program and Processes.

Organizational Structure - Review the organizational structure and educate clients on how their structure impacts the administration of the Adviser’s compliance program.  Review lines of supervision between institutional entities for effectiveness and compliance with regulatory rules and policies.

Associated Person Training – Create the outlines or agenda’s for the training sessions required by rule in areas such as Annual Compliance Meetings, Anti-Money Laundering, Needs Analysis, Firm Element training etc.  In addition, prepare presentation materials, provide sign-in/sign-out documentation and conduct presentations on-site using to assure compliance with regulatory delivery standards.

Development or Restructure of Compliance Programs – Devise a program for new Broker Dealers or review their existing compliance program.  Recommend changes across entire program in such areas as supervisory structure, written policies and procedures, documentation creation and storage and correct any areas missing documentation or analysis.  Assist in the implementation of firm procedures to administer the compliance program and develop a system to administer the compliance program on an ongoing basis, ideally with reallocation of internal resources as available.

Supervisory Structure - Review existing structure to determine if reporting lines are complete and effectively supervise registered and non-registered personnel and assure that all RRs have been notified of the identity of their supervisors and vice-versa.  Correct any structures that allow for self-supervision.  Assure that the supervisory structure is properly documented in the Broker Dealer’s files.

Product Specific Issues – Review and advise on product specific compliance and operational risks and issues for areas such as Mutual Funds, Variable Annuities, Municipal Securities, Options etc.  Recommend any needed enhancements of written procedures, supervisory practices or methods of documentation for the products.

Registered Representative Supervision – Train new registered personnel on regulatory and Firm procedures to proactively reduce the chance of non-compliant behavior.  Review and enhance systems for supervising RRs and how their activity is documented.  Provide branch office inspections to assess RR and branch adherence to regulatory policy and procedure.   

Heightened/Special Supervision – Determine if producing managers at the Broker Dealer have triggered the need for heightened supervision and determine if the Firm qualifies for the Limited Resources exception.  Upon having a qualified producing manager or where the Firm or Regulators deem an associated person’s behavior merits a plan of Special Supervision, create and assist in the administration of heightened/special supervision plans.

Annual Internal Inspection and AML Tests – perform annual inspections and tests as required by regulation.

NASD Registration – Assist new broker/dealers or existing ones to create or change their CMAs, complete necessary disclosure documentation to become registered broker dealers. Advise management on  the key aspects of establishing an effective compliance program once registration becomes effective.

Sarbanes-Oxley Compliance - Determine how SBUX applies to the firm; review the written procedures, documentation and the implementation of the procedures in throughout the firm to evaluate and as necessary make recommendations to enhance compliance with the Sarbanes Oxley legislation.

Compliance Personnel Training– Provide a review of regulatory and Firm policies and procedures to educate new personnel on the compliance program.  Train personnel on effective methods or procedures to effectively administer a compliance program.  Educate and detail the importance of documentation and provide training and assistance on fully documenting the Broker Dealer’s compliance program.

Bridge Transitions for Compliance Positions - Assist the firm in the administration, application and documentation of the compliance program while a change in personnel is in progress to assure that compliance and supervisory processes are not temporarily interrupted as new personnel acclimate to the firm.

Business Continuity Plans – Assist firm in the drafting a complete disaster recovery plan that addresses all key areas including an annual review, testing procedures and the training of employees on all aspects of the plan for disaster recovery.  Assure that the Adviser’s disclosure and notifications regarding the Plan are complete and accurate.

Compliance Issues for New Products – Review new products for management and provide detailed needs for written procedures, supervisory obligations, necessary documentation and an assessment of the added compliance and operational risks introduced by adding the product.