Back in September, the North American Securities Administrators Association (NASAA) released a series of recommended best practices for state advisor firms’ compliance programs. The best practices are a result of a NASAA sweep and subsequent report completed and released this year. According to a NASAA press release, the following are recommended best practices:
Category Archives: Compliance Program
First Internal Audit
September 10, 2005
Has your investment advisor firm completed its first annual review or internal audit of its compliance program?
Written Policies for Block Trades
July 25, 2005
Does your firm implement transactions on an aggregate (a/k/a bunching or block trade) basis? If so, have you established written policies and procedures laying out your firm’s aggregate trading activities? Do you disclose those procedures in your firm’s Form ADV or disclosure brochure?
Regulators have been emphasizing the need for investment advisors to develop and maintain a culture of compliance. Of course, one of the best ways to implement a culture of compliance is for the firm to establish adequate training and continuing education programs.
Anti-Money Laundering Procedures
June 28, 2005
You may have heard that anti-money laundering (AML) reviews have become a routine part of regulatory examinations for broker/dealers. However, are you aware that as an investment advisor, your AML procedures (or lack thereof) may be reviewed as well?
Emails Are Under Scrutiny
June 25, 2005
Is your firm keeping its emails? Have these records been kept in an electronic, searchable format? Can you promptly retrieve an email from five years ago? These are questions that investment advisors are now facing during routine exams by the SEC. As you prepare for your next exam, here are few items to consider.
Texas Proposes Written Supervisory Procedures Rule
June 14, 2005
In light of the SEC’s new rule requiring federally registered investment advisor firms to adopt and implement written compliance programs, many state registered firms are wondering if state regulators will require written supervisory systems too.
Has your registered investment advisor firm implemented written compliance procedures? Has your Chief Compliance Officer signed off on those procedures? Have the procedures been reviewed and updated since October 5, 2004, the date they were required to be in effect? These are all questions that the SEC will be asking during an examination.
SEC Guidance Is Arriving for New CCOs
May 18, 2005
Are you a newly appointed Chief Compliance Officer of an SEC registered investment advisory firm, but not completely sure of the full breadth of your responsibility? If so, you definitely aren’t alone.
