Don’t wait until the regulators appear at your door with a four page document request list for an exam to focus on your ongoing RIA Compliance Requirements. I have worked with many RIA firms that unfortunately have not proactively confirmed and reviewed their firm’s documents on an ongoing basis therefore were not prepared in such a circumstance. It is always better to be proactive and confirm that you have all the documents required under the books and records rules and that your documents are current and up to date.
For example, your policies and procedures manual-when did you last review it?, have changes been made to mirror your business model?; your business continuity plan-does your document explain your firm’s succession plan?; Form ADV Part 1-are all the relevant sections updated within the last 30 days to be current with how your firm operates?; Form U4-is Item 13 Outside Business Activities current and up to date for each of your Investment Advisor Representatives?; Form ADV Part 2A Brochure-similar to your ADV Part 1, is your Brochure current and up to date with how your firm is currently operating?; Form ADV Part 3B Brochure Supplement-is this document current with any new disciplinary matters?; trading blotters-do you have one?; corporate documents-are they up to date with any changes made to your entity?; documentation of your testing of your policies and procedures-have you actually met your testing requirement and documented that you have done so? This is a brief list of some of the required documents. As you can see, if you are not proactive with having your required documents up to date, meeting the deadline of the document request list will be daunting.
If you need help with your ongoing RIA compliance requirements, call Registered Advisor Services today for assistance!