RIA Compliance Consulting Program

A perfect initial filing means nothing a year later. When you take on the responsibility of being a registered investment advisor, your firm has a duty to maintain everything in a timely fashion. Otherwise, you might find yourself in trouble with regulators. Often, RIAs are ill-equipped to handle the constant updates and modifications to their registration documents — but we can help! We provide maintenance on, but not limited to:

• Forms ADV 1 and ADV 2
• Forms U4 and U5
• Client agreements
• Business continuity plan
• Compliance manual
• Privacy policy
• Code of ethics
• Solicitor arrangements
• IARD/CRD account servicing

One facet of the annual renewal process is updating and amending numerous firm documents. Having all the proper documentation prepared is only half of the renewal process. You’ll still need all of those items dispatched to the proper offices and authorities on a timely basis. RIA Registrar has the experience to make the RIA renewal process go smoothly so that you may continue doing what you do best, accommodating the needs of your clients.

The RIA Registrar Annual Renewal Includes:

• Updating the ADV I, ADV 2, and all regulatory documents
• Delivery of all fees to the appropriate authorities: A perfectly prepared document that arrives at its proper destination without the required fees does your firm no favors. We organize everything for your renewal so that the right agencies receive the right fees, and on time.
• Assisting with any additional requirements and updates: During the preparation for the renewal process, various issues may arise such as changes in your fee schedule, services of your firm, or address changes. Also, we will notify you of any other applicable filing you may have to submit, such as your SEC 13F Filing. As your back-office support team, we can assist you in resolving those matters and submitting the appropriate filings.

As an RIA, all advertisements must be truthful and accurate, and any advertising that is misleading, fraudulent, or deceptive is prohibited. So before you send out your materials, let us review and provide commentary according to advertising rules and applicable state regulations. This review includes, but is not limited to, the following:

• Business cards
• Letterhead
• Seminar presentations
• Direct mailers
• Newsletters
• Websites
• Client correspondence

Rule 204-2 of the Investment Advisers Act, usually referred to as the “Books and Records Rule” gives an extensive list of the books and records to be maintained. The following is just a sampling of what is required:

• Ledgers and other records of assets, liabilities, reserves, capital, income and expense accounts
• Bank records such as checkbooks, statements, canceled checks and cash reconciliations
• Financial statements and client invoices related to the investment advisor’s business
• Correspondence relating to recommendations and advice, payment or delivery of securities and money and orders to buy or sell securities
• Records of powers of attorney and similar documents given by clients
• Copies of all notices, advertisements, newspaper articles, etc, distributed by RIAs
• Copies of the firm’s code of ethics
• Records on all Investment Advisor Representatives associated to the RIA
• Articles of incorporation and/or partnerships
• Executed client agreements
• Evidence of client suitability

It takes a specific skill set to effectively manage large-scale records collections. The extreme number of records that must be maintained is compounded by the time span involved. Then there is the caveat that just because you may have these records, in the event the authorities want to review them, they must be readily accessible.

To properly maintain your firm’s records, you need a dedicated team with the experience to help you manage and handle large number of records spanning several years.

Professional training and education make a huge difference in the success of a RIA. RIA Registrar has the essential tools necessary to perform a comprehensive review of policies and procedures. Including:

• Webinar Training 206(4)-7 Review: Monthly webinar training and corresponding checklist to document review of your supervisory procedures.
• Mock Audits
• Audit Preparation/Audit Completion: A review of state/SEC required documents requested for an audit or state examination.
• Compliance Calendar: We provide a monthly compliance calendar to remind you of required books and records. The compliance calendar includes, but is not limited to, the following:
  • ADV delivery requirements
  • Privacy policy updates and delivery
  • Personal securities holdings
  • Quarterly securities transactions
  • Firm due diligence

No law requires RIAs to retain an outside agency for compliance services. However, in the real world, most firms realize the importance of support to maintain a compliant RIA. Many do not foresee the amount of work it takes to comply with ongoing deadlines, ad hoc filings, renewals, audit support, and an overall attention to detail.