Securities Exchange Commission (“SEC”) Rule 206(4)-7 under the 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. SEC Rule 38a-1 under the Company Act imposes parallel requirements on funds.
RRS offers customized solutions to help your firm meet these requirements. Whether you want a mock SEC examination utilizing regulatory techniques that include transactional and forensic level testing, or a high-level review to supplement your own internal reviews, RRS can help. Both levels of service include an assessment of your firm’s overall compliance program, including a regulatory risk assessment combined with a policies and procedures GAP analysis to determine your compliance with industry rules, regulations, and “best practices.”
Comprehensive Compliance Examinations – RRS offers mock regulatory examinations that combine a regulatory risk assessment and policies and procedures GAP analysis with transaction level forensic testing to identify potential violations or deficiencies.
RRS implements this review through a four stage process involving: 1) pre-examination planning – risk assessment and scope; 2) onsite examination and testing of your compliance program; 3) compilation and vetting of RRS’ analysis and findings with Senior Management; and 4) delivery of a written report and regulatory risk assessment and policies and procedures GAP analysis.
High Level Compliance Program Reviews – Similar to the Comprehensive Compliance Examination, this review provides a Regulatory Risk Assessment and policies and procedures GAP analysis with a limited amount of testing (conducted onsite or offsite), customized to fit your needs and budget.
Specialized Compliance Reviews – 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.
Litigation and Expert Witness – RRS provides a comprehensive suite of litigation support and expert witness services designed to assist firms and securities lawyers with the regulatory, enforcement and litigation matters involving investment adviser and broker-dealer clients. Our Consultants have extensive industry expertise and experience as senior level officials with regulatory organizations. We have significant experience in creating expert reports, providing testimony in arbitration and civil proceedings, and have been accepted by regulatory organizations as Independent Consultants resulting from sanctions imposed in enforcement actions.