The North American Securities Administrators Association (NASAA) published their coordinated exam findings of 1170 state registered investment advisers from January-June 2015 in 42 jurisdictions. The majority of these advisers were small firms with one Investment Adviser Representative. Of this total group, for 324 advisers this was the first time they were examined by the state regulators. The top three deficiencies included approximately 70% of the firms examined were deficient in their books & records, 50% in contracts with their clients and 40% in Form ADV filings for their firm. These percentages have increased since 2013. For a complete view of their findings review the report in its entirety. Let this help you test your firm’s compliance records to be certain you are on top of what the state regulators are looking for when they come to exam your firm.
