Rule206(4)-7 under the Advisers Act requires an SEC-registered investment adviser to appoint a Chief Compliance Officer that is competent and knowledgeable regarding the Advisers Act and empowered with full responsibility and authority to develop and enforce appropriate policies and procedures for the adviser. State registered investment advisers are required to appoint someone responsible for the supervision and compliance of the investment adviser.
FINRA Rule 3130 requires that FINRA-registered firms designate and identify on their Form BD, one or more principals to serve as a Chief Compliance Officer. Additionally, many other types of advisers and financial services firms have a business preference to formalize their operations and wish to appoint someone to hold a fractional compliance/supervisory role.
Properly trained compliance professionals are essential to the success of a compliance program – and dedicated internal compliance staff is hard to come by. All too often, investment advisers and other financial services firms hastily fill a vacant compliance position, to their detriment. Fractional resources can be particularly helpful to establish a compliance framework and develop a compliance program for a newly launching investment adviser, broker-dealer, or other financial services firm, as well as to help bridge a gap or provide additional resources for an already established investment adviser, broker-dealer, or another financial services firm.
Coast to Coast Compliance understands that investment advisers and other financial services firms experience urgent situations that result in an immediate need to fill a vacancy and our goal is to provide a flexible alternative option. Coast to Coast Compliance can provide a seasoned compliance professional to serve in an executive role (such as Chief Compliance Officer, Compliance Officer, etc.) or serve as an additional resource, which can be structured on a temporary, interim, fractional, or otherwise, dependent on the specific needs of the firm.