Is your Compliance Program in Order?

The SEC has sanctioned and fined and investment adviser because it failed to implement an adequate compliance program as required by Rule 206(4)-7.  One of the violations cited was using a template manual without tailoring it to the firm’s business.  Pulling a manual off a website is not complying with the Rule.  I can’t tell you how many manuals I read each year and when I ask if the firm does “x” or “y” in the manual, they didn’t even know it was in the manual.

I understand that investment advisers are busy.  If you can’t manage your compliance program on your own – get help.


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