Policies and Procedures/Annual Review

Fortius Financial Advisors and Bollinger settle case of poor compliance P&P that didn’t prevent theft of client funds.  SEC proceedings in the matter of Fortius Financial Advisors, LLC, Jeff M. Bollinger, and Gary E. Oliver

Bollinger was responsible for adopting and implementing Fortius’ compliance program. Between 2003 and August 2012 (throughout the entirety of Oliver’s association with the firm), Fortius only used one compliance manual, which Bollinger created in 2003 from an off-the-shelf template that he obtained from a compliance consulting company (the “Compliance Manual”). However, for significant portions of the Compliance Manual, Bollinger failed to fill in the blanks or edit significant portions of the template to specifically address risks associated with Fortius’ operations.

Rule 206-4(7) requires the adoption and implementation of written policies and procedures reasonably designed to prevent violation of the federal securities laws and to review those policies and procedures annually for their adequacy and the effectiveness of their implementation.

 

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