Annual 206(4)-7 Review

RIA Compliance

Annual 206(4)-7 Review

Compliance Services for Established RIAs

ria compliance consultant

Our review and testing includes the following:

SEC Rule 206(4)-7 requires each registered advisor to review its policies and procedures annually to determine their adequacy and the effectiveness of their implementation. We have a comprehensive audit program to determine if all applicable areas of your business have been included in your policies and procedures, and we test each are to determine the effectiveness of the implementation. 

  • Firm Risk Assessment - we will conduct a risk assessment/analysis of the Firm's compliance program and evaluation of the existing internal controls

  • Overall integrity and effectiveness of the Firm's Policies and Procedures - we will review the Firm's Policies and Procedures to determine the adequacy and the effectiveness of their implementation.  In addition, we will determine if the Policies and Procedures are designed to prevent, deect, and correct violations of the Investment Advisers Act of 1940.  At a minimum, the following elements will be reviewed:  

  • Portfolio management processes, including allocation of investment opportunities among clients and consistency of portfolios with clients' investment objectives, your disclosures to clients, and applicable regulatory restrictions.  

  • The accuracy of disclosures made to investors, clients, and regulators, including account statements and advertisements.  

  • Proprietary trading by you and the personal trading activities of your supervised persons, and review the implementation of these procedures.

  • Safeguarding of client assets from conversion or inappropriate use by your personnel.

  • The accuarate creation of required records, such as trade blotters, ADV disclosures and their maintenance in a manner that secures them from unauthorized altercation or use and protects them from untimely destructions.

  • Safeguards for the privacy protection of client records and information.  

  • Trading practices, including procedures by which you satisfy your best execution obligaton, use client brokerage to obtain research and other services (referred to as "soft dollar arrangements"), and allocate aggregated trades among clients.   

  • Marketing advisory services, including the use of solicitors.

  • Processes to value cient holdings and assess fees based on those valuations.

  • Review the Code of Ethics/Gifts and Entertainment/Privacy Policy and provide recommendations.

  • Review Business Continuity Plan and provide recommendations; and

  • Review any recent material changes to the compliance policies and procedures.  

  • At the conclusion of the review we will provide a detailed Annual 206(4)-7 Report including reviews conducted, findings, and recommendations.  

Annual Updates

Annual Updates

SEC and State-Registered Advisors are required to amend their Form ADV each year by filing an annual updating amendment within 90 days of fiscal year-end.  For the majority of RIAs who are on a calendar year-end, this deadline is March 31st.  When the annual updating amendment is submitted, updated responses must be submitted on the Form ADV and affiliated schedules, in addition to the Firm Brochure and Brochure Supplements.  Many advisors also use this time to mail their clients the revised required disclosures.  

 

Polaris Compliance Consulting can assist you with the required annual updates by doing the following:

  • PCC will review the firm's Form ADV Parts 1A and 1B and update as needed.

  • We will review the firm's disclosure brochures (Form ADV Parts 2A & 2B) and update as needed.

  • We will review/update/provide any addtional state-specific documents required to be submitted in order to be compliant with your State's Annual Renewal requirement. 

  • We will submit the Form ADV Parts 1 and 2 electronically. 

  • PCC will provide unlimited e-mail or phone access 7 days a week to answer any related compliance questions until the Annual Renewal process has been completed.  

Other Compliance Services

Other Compliance Services

  • Monthly compliance checklists

  • Quarterly assessment to determine if Form ADV amendments are required

  • Advertising related reviews, which include business cards, letterhead, seminars, direct mailings, newsletters, websites, etc.

  • Any necessary Form ADV filing amendments including the Annual Update Filing

  • Notifications from our firm to yours of new regulatory updates/requirements

  • Customized training plan for all associates

  • Customized or template of Written Policies and Procedures manual with all of the current rules and regulations, tailored to your firm's business

  • Customized or template Business Continuity Plan tailored to your firm's business and associates

  • Customized or template of Privacy Policy

  • Customized or template of Code of Ethics

  • Customized or template of Firm Brochure, or Firm ADV Part 2A, disclosure document to provide to new and existing clients

  • Customized or template of Brochure Supplement, or Form ADV part 2B, disclosure document for each required Investment Advsior Representative, to provide to new and existing clients

  • Assistance in responding to regulatory inquiries

  • Assistance with regulatory examinations

  • Assistance with any licensing and registration matters (State, SEC, Series 65, hiring, terminations, etc.)

  • Chief Compliance Officer and associate training at least semi-annually

Thank you for your interest!

Contact us for more information:

Disclaimer: Polaris Compliance Consulting, LLC is not a law firm, and we do not give any legal advice. As a consulting firm, we give our personal interpretation of the rules and regulations based on our experience, and we cannot guarantee that any areas advised will be favorably viewed by regulators.