Customized Investment Adviser Compliance Policies and Procedures Manual
As a registered investment adviser, you are required to adopt and implement written policies and procedures (a manual) that are reasonably designed to prevent violations of the securities laws. Your firm’s compliance policies and procedures must be designed to address the individual operations and specific conflicts of interest applicable to your firm’s business.
The IA compliance manual is designed specifically to address the fiduciary and regulatory obligations applicable to your business. The manual is designed to be practical and functional so that it can be effectively implemented by your firm’s chief compliance officer.
The IA compliance manual addresses the following compliance areas:
- Portfolio management processes, including allocation of investment opportunities among clients and consistency of portfolios with clients’ investment objectives, your disclosures to clients, and applicable regulatory restrictions;
- Designation of a chief compliance officer and oversight and supervision of the effectiveness of the firm’s compliance program;
- A code of ethics and insider trading policy designed to address ethical standards for employees and conflicts of interest and reporting requirements related to personal trading;
- Policies addressing conflicts of interest related to gifts and entertainment, outside business activities, and political contributions (“pay to play”);
- The accuracy of disclosures made to investors, clients, and regulators, including account statements, advertisements, Form ADV and Form PF;
- Custody and safeguarding of client assets from conversion or inappropriate use by your personnel;
- The accurate creation of required records and their maintenance in a manner that secures them from unauthorized alteration or use and protects them from untimely destruction;
- Safeguards for the privacy protection of client records and information;
- Trading practices, including procedures by which you satisfy your best execution obligation, use client brokerage to obtain research and other services (referred to as “soft dollar arrangements”), and allocate aggregated trades among clients;
- Electronic communications including the use of social media;
- Performance advertising and marketing of advisory services, including the use of solicitors;
- Anti-money laundering plans;
- Guidelines for working with ERISA clients under DOL oversight;
- Addressing client based issues such as Diminished Capacity;
- Initial and ongoing oversight of Third Party Service Providers;
- Processes to value client holdings and assess fees based on those valuations; and
- Disaster recovery and business continuity plans.
The IA compliance manual also includes customizable forms that the firm can use for employee reporting and compliance documentation. For more information about our fully customized investment adviser compliance manual, please click here, call us at (800) 800-3204 or email us at email@example.com.