Description
This sample written supervisory procedure/compliance manual section for an investment adviser firm that may have an insurance only agent, who is not investment adviser representative licensed, in attendance at an investment advisory client meeting. This sample WSP/compliance manual section also includes an example of a non-licensed meeting attendee acknowledgement. An investment adviser firm should not use this sample WSP/compliance manual section without reviewing the applicable securities regulator’s rules for investment adviser representative licensing requirements.
Please understand that this is merely a sample or template written supervisory procedure/compliance manual section. It has not been customized to your investment adviser firm or your regulator’s requirements. It’s not a substitute for working with an investment adviser compliance professional and legal counsel. You will need to carefully review and finalize this sample supervisory procedure/compliance manual section for your investment adviser firm before you start to utilize it. For additional details about the limitations of this sample document, please refer to the disclosure page with the sample written supervisory procedure/compliance manual section.
Included with Bronze, Silver, Gold and Platinum Packages. Initially posted in December 2017.
Disclosures
This is a sample section for a compliance manual or written supervisory procedures/code of ethics (WSP/CoE) for use by your investment adviser.
This sample section is not intended to detect or prevent fraud, selling away, Ponzi schemes, undisclosed outside business activities, inaccurate or false fee calculations, theft, misappropriation or unlawful conversion of client funds.
Due to changes of investment adviser laws, rules regulatory interpretations and enforcement actions, this sample section may become outdated and need to be updated or discontinued.
This sample section is not a substitute for retaining a compliance professional to advise and assist you as the purchaser regarding your investment adviser’s compliance program.
This sample document is merely an example for general reference and educational purposes. RIA Compliance Consultants, Inc. is providing this sample document to the purchaser on an “as is” basis with no warranty or guaranty whatsoever.
This sample document should be considered a starting point, and purchaser should not treat this sample compliance manual section as a final document ready for use. The sample compliance manual has not been customized to the purchaser’s business model, the specific investment advisory rules applicable to the purchaser’s investment adviser or the written supervisory procedures and code of ethics of purchaser’s investment adviser.
Unless otherwise agreed to in writing, you understand that RIA Compliance Consultants, Inc. is not responsible for customizing this sample section, implementing the use of this sample section, updating this sample section, otherwise preparing your investment adviser’s written supervisory procedures or code of ethics, or notifying you of changes to the investment advisor laws and rules.
This sample compliance manual may not be applicable or appropriate for every investment adviser. The purchaser should not consider a sample compliance manual section purchased from our online store as an exhaustive, comprehensive or definitive analysis or list of the items necessary to meet the purchaser’s obligations under the applicable investment adviser laws and rules.
This sample compliance manual section is not intended to detect or prevent fraud, selling away, Ponzi schemes, undisclosed outside business activities, inaccurate or false fee calculations, theft, misappropriation or unlawful conversion of client funds.
Due to changes of investment adviser laws and rules, this sample compliance manual section may become outdated and need to be updated or discontinued. RIA Compliance Consultants, Inc. will not be providing any subsequent updates of this sample compliance manual section to the purchaser. Likewise, RIA Compliance Consultants, Inc. will not be monitoring and reporting to the purchaser any issues related to the use of this sample compliance manual section.
Since this sample document may not reflect the specific investment advisory requirements of the purchaser’s securities regulator, the purchaser should check with the securities regulator(s) with jurisdiction over its investment adviser or review any applicable rules before using this sample compliance manual section.
This sample compliance manual section is not a substitute for retaining a compliance professional to advise and assist the purchaser regarding its investment adviser’s compliance program. Unless otherwise agreed to in writing, the purchaser understands that the purchaser has not engaged RIA Compliance Consultants, Inc. in a consulting relationship by merely purchasing or utilizing a sample form. Additionally, the purchaser understand that unless otherwise agreed to in writing, RIA Compliance Consultants, Inc. is not responsible for customizing this sample compliance manual section, updating the sample compliance manual section, preparing the purchaser’s compliance manual, written supervisory procedures or code of ethics, or notifying the purchaser of changes to the investment adviser laws and rules.
Purchaser is not authorized to re-sell this sample document nor license the use of this sample document to a third-party.
Delivery
If this product involves the purchase of a WSP/CoE update section on a la cart basis (not part of an annual compliance program engagement), the purchaser will have three ways to access this sample document: 1) Following payment, the purchaser will be redirected to a thank you page with a button to download the sample document; 2) The purchaser will receive an invoice email with a link to download the sample document; 3) If the purchaser has an account or elects to create one at the time of checkout, this sample document can be accessed from the “Downloads” section of purchaser’s My Account page. The purchaser will have 90 days to download sample document, which is limited to 3 downloads during this period.
If the individual intending to make a purchase is affiliated with a firm which has an active engagement with RIA Compliance Consultants for an annual compliance program (“ACP”), WSP/CoE update sectiond are available as part of ACP depending upon the package and do not need to be purchased separately. To access your WSP/CoE section updates, please log into our Knowledge Base at https://www.ria-compliance-consultants.com/my-account/ to download such section update. For detailed instructions on how to access the KnowledgeBase, please refer to the following webpage: KnowledgeBase Instructions
If you experience any issues when making the purchase, please email delivery@ria-compliance-consultants.com .
ACP packages
To the extent that your investment adviser firm currently has an active Annual Compliance Program (“ACP”) engagement with RIA Compliance Consultants, Inc., this sample document may be available as part of that engagement depending upon your firm’s ACP package (e.g., Bronze, Silver, Gold, Platinum and Titanium). Please refer to the “Description” tab within the product to determine whether the sample document is included as part of your firm’s ACP package. If included and your firm (via the individual making payments in our system) has designated you as a team member in our Knowledge Base, please log into our Knowledge Base to download the sample document. (For detailed instructions on how to access the Knowledge Base, please refer to the following webpage: Knowledge Base Instructions.) If not included in your ACP package, you can make an a la carte purchase of the sample document through this product in our online store.
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