“…all registered advisers should periodically undertake a comprehensive review of their operations to identify any gaps in their compliance policies and procedures, make sure that their policies are tailored to the organization, and update them if there have been changes in the firm’s activities or products.”
Chief, Asset Management Unit, SEC Enforcement Division,
December 18, 2012
By law, registered investment advisers must review their compliance programs “no less frequently than annually.” Investment advisers that registered with the SEC on or prior to March 30, 2012, as a result of the Dodd-Frank Act, should be planning their annual reviews now.
As noted by the SEC in adopting Rule 206(4)-7, these reviews should consider, among other things, changes to adviser and affiliate business activities, changes to applicable regulations, and the import of any compliance matters that arose in the previous year. The reviews also should be designed to determine the adequacy of the adviser’s compliance policies and procedures and the effectiveness of their implementation.
Let the experts at ACA Compliance Group conduct your firm’s annual compliance program review. ACA’s team of former SEC examiners and in-house compliance professionals performs hundreds of these reviews each year. These engagements include
Now is also the time to ensure your firm’s readiness for an SEC examination. In particular, as discussed in our October 10, 2012 alert, newly-registered investment advisers should be taking steps to confirm their preparedness for an SEC presence exam.
Do not wait until it is too late – schedule your annual compliance program review or mock SEC presence exam now. For more information on ACA’s services, please email Luke Wilson or call (312) 505-0307.