Failing to conduct an annual review has been a consistently cited compliance issue in SEC examinations and can result in fines and penalties. 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, also requires broker-dealers and other FINRA-regulated firms to annually prepare a report detailing the firm's supervisory control system, which summarizes the test results, significant identified exceptions, and any additional or amended supervisory procedures created in response to the test results.
Coast to Coast Compliance can perform an independent annual review of your firm’s compliance program. We will conduct a comprehensive review of the consistency and adequacy of your firm’s policies and procedures, as well as the completeness and effectiveness of its overall compliance program. We will provide a written annual review report documenting the scope of our review, relevant findings, and any resulting recommendations.
Other Advisers/Financial Firms: Also, for other types of investment advisers or financial services firms, a similar project may be relevant or become of interest to the firm through the course of due diligence on behalf of a service provider, investor request, or otherwise. In any event, Coast to Coast Compliance can help provide an independent view of your firm’s compliance program for investors, regulators, senior management, etc.