Whether you’re looking to fulfill your annual SEC compliance program review as mandated by Rule 206(4)-7 of the Investment Advisers Act of 1940, your FINRA required annual review, need to conduct a compliance gap analysis to determine if your firm is acting within the remit of its FCA Part 4A license permission, or want some assistance with thematic compliance program reviews or consistent regulatory consulting throughout the year, we can help.
Conducting periodic testing of your firm’s governance and control arrangements, as well as its policies and procedures, is essential to help avoid the cost and reputational risk of future scrutiny and potential enforcement.
Regulatory gaps, failings or weaknesses can result in fines, reputational damage, and even criminal sanctions.
Gain the peace of mind that comes from working with the most trusted and experienced GRC advisor in the financial services industry. With former SEC, FINRA, FCA, NFA, CFTC, OCC, and state regulators along with former along with former Chief Compliance Officers and senior compliance managers from prominent financial institutions, we offer a deep understanding of the regulatory landscape and the holistic use of technology to maximize efficiencies and provide true value.
Investment advisers often have robust compliance assessment programs in place to ensure their staff and control environment remain a well-oiled machine. Most of the time, such testing programs are front of mind and on top of the daily, weekly, or monthly to-do list.
Yet over the past year – as compliance professionals have been forced to work from home during a global pandemic that comes with additional family obligations, enhanced day-to-day surveillance of staff, and adapting to changing expectations - testing has fallen to the bottom of the priority list. Unfortunately, the obligation to forensically test and/or stress test your compliance program remains.
Download our Compliance Testing Action Plan to help you and your firm get started.
The amendments to Investment Advisers Act Rule 204-2 will require advisers to maintain additional records related to the calculation and distribution of performance information.
Communications record keeping obligations which include phone taping, are likely to prove particularly challenging when it comes to the cost of compliance and complexity of systems requirements.
The electronic communication mediums that investment advisers use to conduct business continue to evolve, posing a challenge to the compliance community’s ability to retain and adequately supervise
The SEC has been paying close attention to discrepancies in Form ADV filings, specifically reviewing assets under management. When Annual Updates are due, it’s important to pay close attention to how you calculate your regulatory assets under management (RAUM).
FINRA Rule 1250 requires registered persons to participate in Continuing Education (“CE”), with both Regulatory Element and Firm Element training. We break down these categories and how to differentiate them.
When opening a new office in the securities industry, FINRA’s Rule 3110(f) outlines the role of each associated office and registration requirements for each office type.
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