With the new year upon us, SEC registered investment advisers and most state registered investment advisers are reminded that in addition to adopting and implementing written policies and procedures, registered investment advisers are also required to review policies and procedures at least annually for the adequacy and effectiveness of the implementation of such policies and procedures. When conducting a review, investment advisers should consider items in your written policies and procedures that may need to be added, revised, or updated due to exam deficiencies, violations that have occurred in relation to the existing policies and procedures, changes in your registered investment adviser’s business model or regulatory changes. Examples may include changes in your investment adviser’s registration requirements or changes in policies concerning the use of social medial, political contributions or supervising branch office locations.

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