Buying an “off the shelf” compliance manual is often a starting point for newly registered investment advisers. But that is all it is – a generic document describing the areas you most need to cover in establishing your compliance program.
According to the Office of Compliance Inspections and Examinations in a recent National Exam Program Risk Alert, SEC staff may view the use of an off-the-shelf manual as one of the hallmarks of an ineffective compliance program.
Specifically, the alert identifies as an example of deficiencies or weaknesses when “compliance manuals are not reasonably tailored to the adviser’s business practices.” Examiners want to see that your compliance program takes into account important individualized business practices, such as your:
- Investment strategies
- Types of clients
- Trading practices
- Valuation procedures
- Advisory fees
At Hardin Compliance, our expert team is both qualified and ready to help. We know it takes time, regulatory expertise, and an understanding of a firm’s business model to create a compliance manual that addresses your firm’s specific risks and conflicts.
We will review your current manual to determine whether it addresses the most recent regulations and industry best practices. We will then provide you with practical advice on how to update your policies and procedures. Our goal is not to reinvent the wheel – so if you are already doing the right thing we help you develop the documentation to prove it.
Our compliance consultants work with a wide range of investment advisers, including:
- Retail advisers
- Hedge fund managers
- Mutual fund companies
- Private equity firms
- Broker dealers
Developing a Custom Compliance Manual
Developing a customized compliance manual that meets regulatory requirements and stands up to scrutiny by the SEC and FINRA is strongly recommended.
At Hardin Compliance Consulting, we take the time to really understand your business and operations so we can make sure your compliance policies and procedures are tailored to your firm’s business.
We know that compliance manuals that are not current could represent a significant regulatory risk. If your manual contains information and policies that are no longer in practice, outdated information about your firm, and details on investment policies that are no longer pursued, then these all become fodder for regulatory examination.
We work with you to create an appropriately customized manual and then help you keep your compliance manual up-to-date as your investment strategies change, personnel turn-over, and new and emerging rules and regulations come into play.
We’re ready to help. Call our main office at 724-935-6770 or visit our Contact Us page today.