Coast to Coast Compliance helps give your firm and staff the credit it deserves for an effective compliance program and a strong culture of compliance.
Failing to conduct an annual review has been a consistently cited compliance issue in SEC examinations and can result in fines and penalties. It is one of the first items examiners ask to see, and an undocumented review is difficult to defend after the fact.
Rule 206(4)-7 under the Advisers Act requires SEC-registered investment advisers to annually review their written policies and procedures to determine their adequacy and the effectiveness of their implementation.
FINRA Rule 3120 requires broker-dealers and other FINRA-regulated firms to annually prepare a report detailing the firm's supervisory control system, summarizing test results, significant identified exceptions, and any additional or amended supervisory procedures created in response to those results.
Coast to Coast Compliance performs an independent annual review of your firm's compliance program. We conduct a comprehensive review of the consistency and adequacy of your policies and procedures, as well as the completeness and effectiveness of the overall program. You receive a written annual review report documenting:
Firms often pair the annual review with a mock SEC examination. The review satisfies the rule; the mock exam pressure-tests how the program holds up under live questioning.
For other types of investment advisers or financial services firms, a similar project may become relevant through due diligence on behalf of a service provider, an investor request, or otherwise. In any event, Coast to Coast Compliance can provide an independent view of your compliance program for investors, regulators, and senior management.
To scope an annual review for your firm, contact us.
Common questions about working with a securities compliance consulting firm.
.svg)
