Brace yourself (again). Ongoing investment advisor compliance is not brain science, but could be - if you don’t have the time. Many investment advisor firms do not normally have the time or capital to expend on compliance, yet they must. They provide their own clients with excellent client services, as they should, but face the ever-present problem of balancing client service with the demanding task of staying on top of all that the SEC and state securities regulators, as the case may be, require of them in the daily, weekly, monthly and annual operation of their businesses.

My investment advisor ongoing compliance support program can help. Keeping in line with my philosophy that you begin with the simplest solution possible and work in reverse, adding only what must be added to become and remain in compliance, my goal is never to impress you with quantity, but with quality. Remember: “less but better.”   

As part of my investment advisor ongoing compliance support program I can provide both annual updating amendments and intra-year amendments to Form ADV Part 1, 2A and 2B, and guidance with respect to the subject matter of those amendments.   

As part of my investment advisor ongoing compliance support program I can provide Investment Advisor Testing & Risk Assessments as well as report on findings from the Annual Review in either a written or verbal format based upon your investment advisor’s preference.

As part of my investment advisor ongoing compliance support program I can conduct an annual compliance meeting with employees and registered persons. In addition, I can provide training materials and personnel certifications.

As part of my investment advisor ongoing compliance support program I can provide updates to your Cyber Security Plans and Business Continuity Plans and in addition can provide simultaneous or annual training in these areas as agreed upon.  

Many of my clients appreciate that I can prepare a compliance calendar or compliance checklist so that while they must maintain a current knowledge of their procedures, they can from a day to day perspective refer to an even more convenient calendar or checklist of duties. As part of my investment advisor ongoing compliance support program I can provide periodic compliance calls in support of the regular duties.

As part of my investment advisor ongoing compliance support program I can update your investment advisor policies and procedures (also known as a registered investment advisor compliance manual, and can also update a completely customized compliance manual that I have previously drafted for you.

The same is true for your Code of Ethics. In order to ensure the most up-to-date documentation I can provide an ongoing review of any existing compliance manual or Code of Ethics;

As part of my investment advisor ongoing compliance support program I can provide an initial and thereafter ongoing Conflict of Interest Inventory and, of course, assist your investment advisor in conflict resolution.

As part of my investment advisor ongoing compliance support program I can conduct email review based upon keyword criteria, random sampling percentage, as well as advise on the most efficient and proper e-mail review procedures;

As part of my investment advisor ongoing compliance support program I can respond to your questions, calls or emails not specifically dealing with other aspects of my compliance retainer.

As part of my investment advisor ongoing compliance support program I can provide reviews and make suggestions as to the proper format and appropriateness of your advertising materials.

As part of my investment advisor ongoing compliance support program my staff and I can assist your investment advisor with annual registration renewals and ongoing Form ADV, Form U-4 and Form U5 registration requirements. We can also administer the IARD Account as a Super Account Administrator. As explained elsewhere, we do the same for broker-dealers via the FINRA Web CRD system.

As part of my investment advisor ongoing compliance support program I can help your investment advisor prepare for SEC examinations wherein I will provide you with an Excel based SEC Document Request List worksheet to prepare for SEC Exam. I can also develop an introductory presentation for the SEC examination.

As part of or separate from my investment advisor ongoing compliance support program I can conduct branch office reviews incorporating the larger services I can providing throughout the compliance retainer program.