Happy New Year! As we start the New Year, investment compliance services should be at the top of registered investment advisors “to do” list! The start of each year brings about the following investment advisor ongoing compliance requirements that need attention:
- Confirm that your renewal fees for 2017 have all been paid and that you have downloaded from FINRA a copy of your Paid Renewal Statement to confirm payment.
- Begin gathering the information for your Annual Amendment filing due within 90 days of your investment advisory firm’s fiscal year end.
- Begin your review of your Form ADV Part 2A Brochure and Form ADV Part 2B Brochure Supplement to be certain the advisory services you provide are still properly disclosed within your compliance documents.
- Within 120 days of your investment advisor firm’s fiscal year end, be certain you provide a copy of your Form ADV Part 2A Brochure and 2B Brochure Supplement to your clients and document that you have done so.
- State registered investment advisors may be required to submit to their state regulator financial statements by March 31, 2017. Confirm with your state regulator if this is a requirement for your firm to meet your investment compliance services.
- Review your firm’s Privacy Policy to confirm no compliance changes are needed.
- Complete FINRA’s certification to confirm who has access to the Investment Advisor Registration Depository (IARD) system on behalf of your investment advisor firm.
- Review Form U4 to confirm that the responses to all the questions are still current and up to date, especially the Outside Business Activities.
- Exempt Reporting Advisors are also required to file an Annual Amendment filing within 90 days of the firm’s fiscal year end. Begin your review of this document and gathering of your firm’s Regulatory Assets Under Management, Number of Accounts, Type of Clients, etc.
- Rule 206(4)-7 under the Investment Advisers Act of 1940 requires registered investment advisors to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder by the Adviser and its supervised persons. Do a review of your written policies and procedures, and document your review, to confirm that the investment compliance services are properly described.
- Confirm that your supervised persons have signed and certified to your advisory firm’s Code of Ethics. Confirm that you have gathered the necessary brokerage statements from your supervised persons, quarterly and annually, to meet the investment compliance services requirement review procedures within the Code of Ethics.
- Most registered investment advisors to private funds are required to file Form PF on either a quarterly or annual basis. Be certain you have determined your filing requirement and deadline to properly meet this important deadline.
This bullet point list is some of the more immediate investment compliance services that registered investment advisor firms need to attend to during the first quarter of 2017. Firms needing assistance with investment compliance services, contact Registered Advisor Services today for more information about how we may partner together to meet your firm’s goals.
