Form ADV Part 2 Rewrite Program

Recent amendments to Form ADV Part 2 require all SEC and state-registered investment advisers to conduct a complete overhaul of their ADV Part 2. U.S. Compliance Consultants can help you transform your ADV Part 2 from its current "check-the-box" format into a publicly viewable brochure with all required narrative disclosures. Our ADV Part 2 Rewrite Program includes:

• Drafting narrative responses to each of the 19 items required in the Firm Brochure (new Part 2A)
• Crafting disclosures about key investment professionals in the Brochure Supplement (new Part 2B)
• Filing your new ADV Part 2 electronically via the Investment Adviser Registration Depository

SEC to State Registration Transition Program

SEC-registered investment advisers with less than $100 million in assets under management are required to transition from SEC to state registration. If you are one of these advisers, you will now be subject to unfamiliar state rules and regulations concerning compliance, custody, capital requirements, advisory agreements, privacy and data security. U.S. Compliance Consultants can help guide your advisory firm through the difficult transition process with our SEC to State Registration Transition Program. Our Registration Transition Program includes:

• Registration of your investment advisory firm in one or more states
• Registration of investment adviser representatives in all applicable states
• Filing all additional state-required documentation
• State-specific compliance manual (including code of ethics)
• Withdrawal of your advisory firm from the SEC

SEC Registration Services Program

Registering with the Securities and Exchange Commission involves far more than just filing Form ADV Part 1. Prior to the effective date of a firm’s registration, an SEC-registered investment adviser is required to have a robust compliance program in place. U.S. Compliance Consultants can provide your advisory firm with a complete registration and compliance solution that satisfies current SEC expectations. Our SEC Registration Services Program includes:

Registration Element

• Setting up the IARD account
• Facilitating the payment of all registration fees
• Acting as liaison with the SEC
• Preparing and filing Form ADV, Part 1
• Preparing the disclosure brochure
• Registering investment adviser representatives
• Making all required notice filings

Compliance Element

• Completing a risk assessment
• Drafting a risk management matrix
• Drafting a fully-customized compliance manual and code of ethics
• Creating a compliance calendar
• Implementing a compliance testing program

State Registration Services Program

U.S. Compliance Consultants understands that most new investment advisory firms registering on the state level are on a tight budget and appreciate a quick turn-around that allows them to be up and running in the shortest time possible. Our familiarity with the state regulatory landscape ensures a smooth and efficient registration process. Flexible payment options also ensure that your new advisory business is not overwhelmed by registration and compliance costs during its formative stage. Most important of all, our "turn-key" registration program allows your advisory firm to begin seeing clients and earning advisory fees the day your firm becomes registered. Please click here to obtain additional information on our "turn-key" registration program for your specific state of registration.

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Registration Renewal Program

Every year, both state and SEC-registered advisers are required to pay renewal fees and file an annual updating amendment via the Investment Adviser Registration Depository (IARD) system. Unfortunately, the IARD system can be a confusing maze of filings, payment options and unintelligible instructions. U.S. Compliance Consultants can serve as administrator for your advisory firm’s IARD account and manage all online filings and annual updates. Our Registration Renewal Program is provided on a 12-month basis and includes:

• Ongoing registration consulting
• Administration of your firm’s IARD account
• Ensuring your renewal fees are paid on time
• Updating Form ADV Part 1 and Part II
• Filing the Annual Updating Amendment
• Making all required state filings
  

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Compliance and Supervisory Procedures

U.S. Compliance Consultants does not offer a "one-size-fits-all" off-the-shelf compliance manual. No filling in the blanks with our compliance manuals. All of our manuals are fully customized to help you create the “culture of compliance” regulators are now demanding. U.S. Compliance Consultants will provide your advisory firm with innovative, cost-effective compliance policies and procedures that reflect current state or federal requirements, including:

• Risk Assessment Procedures
• Supervisory Procedures
• Business Continuity/Disaster Recovery Plans
• Codes of Ethics
• Portfolio Management Procedures
• Insider Trading Policies
• Employee Trading Procedures
• Proxy Voting Procedures
• Annual Privacy Notices
• Soft Dollar Policies
• Best Execution Procedures
• Information Security Programs
• Book and Record Creation and Retention Procedures
• Email Retention Policies
• Anti-Money Laundering Procedures
  

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Compliance Development Program

For those investment advisers that already have an existing compliance program, but are unsure that they are in compliance with current rules and regulations, U.S. Compliance Consultants can provide your firm with the certainty that its compliance obligations are being met.  The Compliance Program Development process begins with a comprehensive review of your firm’s existing regulatory and compliance-related documents and supervisory structure. U.S. Compliance Consultants will revise, replace or overhaul your compliance program and attendant documents as necessary in order to bring your firm’s compliance program in line with applicable regulations and industry best practices.

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Compliance Outsourcing

For SEC-registered advisory firms that are required to have a chief compliance officer, but do not have the expertise or personnel to fill the position, U.S. Compliance Consultants can serve as your chief compliance officer on an on-going basis.

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Investment Advisory Contracts

U.S. Compliance Consultants can review and revise your current investment advisory contracts or provide your advisory firm with customized agreements that best suits your business practices, including:

• Investment Advisory Management (Discretionary and Non-Discretionary)
• Financial Planning Agreements
• Solicitor's Agreements
  

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Mock Compliance Audits

U.S. Compliance Consultants will conduct a mock SEC or state examination of your advisory firm in order to identify potential compliance problems before you are audited. The Mock Audit includes:

• Review Current Records, Policies and Operations
• Conflict of Interest/Compliance Risk Assessment
• Comprehensive Summary Report
• Recommendations to Correct Deficiencies

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Hedge Funds

The formation of private investment funds (i.e., "hedge funds") and the development of compliance programs to govern their operations present unique regulatory challenges. As the compliance consultant to both start-up and established hedge funds, U.S. Compliance Consultants has the expertise to guide you through the process. U.S. Compliance Consultants can provide the established hedge fund with the tools necessary to create a compliance infrastructure and the start-up hedge fund with complete "turn-key" services, including:

• Investment Adviser Registration and Filings
• Customized Compliance Programs
• Private Placement Offering Documents
• Regulation D Filings
• Blue Sky Filings

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