We believe that every aspect of your compliance program should simply reflect how you conduct your advisory business. That allows us to build compliance programs that are simple to use and simple to maintain.
Compliance Consulting Projects
Investment advisers can retain U.S. Compliance Consultants for individual consulting on either an hourly or project basis. Some of our recent consulting projects have included:
- Acting as a liaison with SEC examiners during a regulatory audit
- Drafting disclosures for an adviser’s web site and LinkedIn page
- Revising firm brochures (ADV Part 2A) and brochure supplements (ADV Part 2B)
- Drafting and implementing an adviser’s new social media policy and procedures
- Managing all compliance aspects of a merger between two SEC-registered investment advisory firms
- Conducting annual compliance/training meetings for advisory personnel
- Assisting an adviser with formulating an action response plan to a data security breach
- Creating a business succession plan for a single-person advisory firm
Policies and 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 simplified compliance policies and procedures that reflect current state or federal requirements. Our Policies and Procedures solution includes (as applicable):
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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
Compliance Program Development
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. Our Compliance Program Development solution 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.
Compliance Outsourcing
Managing your advisory firm’s compliance program can be an overwhelming task. But with the full resources of U.S. Compliance Consultants at your disposal, you can have complete confidence that all your regulatory obligations will be met. Working closely with your Chief Compliance Officer and/or compliance staff, U.S. Compliance Consultants will handle all aspects of your compliance program. The comment we hear most often from our outsourcing clients is “you help me sleep at night.”
Our Compliance Outsourcing solution includes:
- Dedicated compliance professional
- Initial mock audit
- Initial and annual risk assessment
- Customized compliance program
- Compliance testing plan
- Regulatory examination support
- Annual review
- Personal trading
- IARD account management
- Annual and interim registration filings
- Disclosure document (e.g., ADV Part 2A and 2B) review and updates
- Monthly and quarterly compliance checklists
- Compliance training material
CCO 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. Our CCO Outsourcing solution includes all services provided under our Compliance Outsourcing solution.
Mock Audit
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. Our Mock Audit solution includes:
- Review Current Records, Policies and Operations
- Conflict of Interest/Compliance Risk Assessment
- Comprehensive Summary Report
- Recommendations to Correct Deficiencies
Annual Review
All SEC-registered investment advisers are required to review their policies and procedures on at least an annual basis. As part of our Annual Review solution, U.S. Compliance Consultants will test the adequacy and effectiveness of your policies and procedures and draft an annual review report that is comprehensive enough to satisfy regulators, while at the same time protects the best interests of your advisory firm.