Rule 206(4)-7 under the Investment Advisers Act of 1940 (“Advisers Act”) requires investment advisers to do three things: 1) implement written policies and procedures designed to prevent, detect and correct violations of the Advisers Act by the adviser and its supervised persons; 2) designate a chief compliance officer responsible for administering the policies and procedures; and 3) review these policies and procedures at least annually for their adequacy and the effectiveness of their implementation. Rule 38a-1 under the Investment Company Act imposes parallel requirements on funds.
RRS offers customized solutions to help your firm meet these requirements. Whether you want a high-level review to supplement your own internal reviews or an independent detailed transaction level review, RRS can help.
Compliance Program Risk Assessments - RRS will assess your firm's overall compliance program, including its risk assessment, internal controls and written policies and procedures, to determine if they comply with industry rules, regulations, and “best practices.”
Internal Controls, Policy and Procedure Examinations - In addition to assessing the adequacy of your firm's compliance program, this service involves high level testing to determine if the implementation of your firm's program is in accordance with established written policies and procedures.
Comprehensive Compliance Examinations - RRS’ most comprehensive service, it combines assessment and implementation with transaction level forensic testing to identify potential violations or deficiencies.
Specialized Compliance Review - RRS performs specialized compliance examinations based upon specific department or rule compliance. Examples include reviews of practices and procedures related to valuation/pricing, best execution/trade management, soft dollars, registration processing and requirements, anti-money laundering, and code of ethics to name a few.
Regulatory Examination Support - RRS helps firms manage regulatory examinations to ensure efficient production of documents and reduce the regulatory burden. In fact, in certain situations, a consultant can be available onsite to help you respond to document requests from regulators. |
