Request Supervised Persons Complete Annual Attestations

As compliance best practice and/or possibly a requirement under an investment adviser firm’s compliance manual, each supervised person of the firm should submit the following items to the firm’s chief compliance officer (“CCO”) or designee on an annual basis:

• Each supervised person should confirm in writing that such individual has re-reviewed and understands the firm’s code of ethics especially any recent changes;
• Each supervised person should complete an outside business activity form and forward to the CCO or designee, which should be reviewed against the investment adviser firm’s policies and also cross-referenced, if applicable, against the disclosures in the firm’s Form ADV and, if applicable, the individual’s Form U4 and Form ADV Part 2B;
• Each supervised person should confirm that his PST and personal holdings have been reported to the investment adviser firm’s CCO or designee;
• Each supervised persons should acknowledge and confirm compliance with the firm’s policies related to texting/messaging clients, use of social media, unauthorized/undisclosed promotion of meme stock, recommending crypto or digital securities, voting proxies, gift giving/receiving, client testimonials and non-client endorsements, and political campaign contributions;
• Each supervised person should complete the firm’s insider survey dislosing any relationships or clients who are insiders of a publicly traded company;
• If the supervised person is also an investment adviser representative, he or she should review and approve Form U4 and Form ADV Part 2B and forward to the CCO or designee; and
• If the supervised person is not licensed as an investment adviser representative, he or she should confirm that he or she is not engaging in activities requiring IAR registration with the applicable state securities regulator and forward to the CCO or designee.

Related Resources:

Rep – IAR Annual Questionnaire

General Disclosure:

The information contained in this sample calendar event is general in nature intended for educational purposes only and is not intended to be a comprehensive analysis of this topic.  This sample compliance calendar event does not necessarily reflect the requirements in your compliance manual. Securities regulations and corresponding deadlines are subject to change, and this calendar event may not reflect the most current requirements.  This calendar event is not intended to constitute compliance consulting advice or apply to any particular investment adviser firm’s specific situation. Please consult the applicable securities regulator’s rules and published guidance for more details and the most current requirements about the topics referenced above.