Well documented written policies and procedures form the foundation for a sound Compliance Program. Rapid changes in regulations, products and services necessitate frequent updates to written policies and procedures manuals. RRS will work with you (on or off site) to understand your firm’s investment philosophy and day-to-day operations to customize procedures that best fit your business model and budget to meet regulatory requirements. RRS’ consultants have the experience and expertise necessary to help you create, review, or update your written policies and procedures to meet applicable State or SEC regulatory requirements.
RRS’ written supervisory and compliance manuals cover the core regulatory requirements including but not limited to:
- Portfolio management processes, including the allocation of investment opportunities and consistency of portfolios with clients’ investment objectives, disclosures, and applicable regulatory and/or client imposed portfolio restrictions.
- Trading practices, including procedures by which your firm satisfies its most favorable execution obligation, uses client brokerage to obtain research and other services (“soft dollar arrangements”), and allocates trades among clients.
- Proprietary and cross trading and the personal trading activities of its employees (this also includes the review of gift and entertainment policies, Foreign Correct Practices Act of 1977, and the whistleblower provisions of Section 21F of the Securities Exchange Act of 1934 (“Exchange Act”)).
- Political activities (i.e., adherence to Rule 206(4)-5, the “Pay-to-Play” Rule).
- The accuracy and completeness of disclosures made to investors, clients, and regulators, including account statements, advertisements, and regulatory filings.
- The safeguarding of client assets from conversion or inappropriate use by advisory personnel (Custody).
- The accurate creation and maintenance of required books and records and policies that secure them from unauthorized alteration or use and untimely destruction.
- Marketing of advisory services, including the use of social media or any solicitors or placement agents.
- Processes to value client holdings and assess advisory fees based on such valuations.
- Safeguards to protect the confidentiality of client information.
- Business continuity planning.
- Implementation of the compliance program.
Written Supervisory Procedures – RRS provides customized written supervisory policies and procedures manuals. From developing an internal control structure to establishing testing methods and cycles, RRS can provide the guidance necessary to ensure that your procedures meet today’s stringent regulatory requirements.
Compliance Manuals – RRS also provides customized desk level compliance manuals that will help to ensure your firm adequately communicates internal policies to investment advisory representatives and employees.
Policy and Procedure Update Services – RRS can review and update your policies and procedures on an ongoing basis to help you keep up with regulatory and business changes. See Compliance Support Services for more information.
Testing Services – RRS can also provide testing services to ensure that your written policies and procedures are properly implemented. See Compliance Examination & Testing for more information.