Whether regulator-driven, investor-driven, or otherwise, Coast to Coast Compliance designs and implements written compliance policies and procedures, or reviews and revises your firm's existing ones.
SEC and state-registered investment advisers are required to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and other laws, and to designate a Chief Compliance Officer to enforce them. Exempt reporting advisers must also implement written policies and procedures reasonably designed to prevent the misuse of material non-public information under Section 204 of the Advisers Act.
Broker-dealers and other FINRA-regulated firms have similar requirements. Under FINRA Rule 3110(b), each firm must establish, maintain, and enforce written procedures to supervise the types of business in which it engages and the activities of its associated persons, reasonably designed to achieve compliance with applicable securities laws, regulations, and FINRA rules.
Through due diligence on behalf of prospective investors or third-party service providers, many other investment advisers, alternative asset managers, and financial services firms find themselves needing customized policies and procedures even where no rule compels it.
A manual only works if personnel know what is in it, which is why implementation usually pairs with firm-wide compliance training.
Policies are only as good as their upkeep. We recommend revisiting them during your annual compliance program review and any time the business changes materially. To get started, contact us.
Common questions about working with a securities compliance consulting firm.
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