STP’s Compliance Reviews, Exams, and Assessments services. As a registered investment adviser, it’s critical to meet regulatory requirements and maintain robust compliance practices. According to SEC Rule 206(4)-7, investment advisers are required to conduct an annual compliance review to evaluate the effectiveness of their compliance policies and procedures. Our services are designed to help you stay compliant with this rule, as well as prepare for SEC mock exams and other regulatory assessments. We offer a comprehensive approach to identify potential compliance gaps, enhance your firm’s compliance infrastructure, and ensure your business remains aligned with the latest regulatory standards. With our expert guidance, you can confidently navigate the complexities of compliance and avoid costly pitfalls.
Annual Compliance Review (Rule 206(4)-7)
Key Components of the Annual Compliance Review:
- Policy and Procedure Assessment: Review and evaluate the effectiveness of existing compliance policies and procedures.
- Testing and Monitoring: Conduct testing of compliance procedures and monitoring activities to ensure they are working as intended.
- Compliance Issues Identification: Identify any compliance issues or gaps that have arisen over the past year.
- Review of Regulatory Changes: Assess any regulation changes and ensure that the compliance program has been updated accordingly.
- Documentation: Prepare a written report regarding the adequacy of the compliance program and assessing the firm’s compliance with its adopted policies.
Importance of the Annual Review
- Regulatory Compliance: Determines that the adviser is in compliance with all relevant regulations and reduces the risk of regulatory violations.
- Risk Mitigation: Helps identify potential compliance risks and provides recommendations and best practices for mitigating risks.
SEC Mock Exams
To help firms assess their compliance with SEC regulations and identify areas for improvement before the actual SEC audit or examination.
Key Components of an SEC Mock Exam:
- Organizational Understanding: Review firm’s structure, including key personnel, ownership and any related entities. Review advisory services offered and overall operating model.
- Document Requests: Collect and review firm’s advisory records, including compliance memoranda and financial statements. Multiple document requests may be used based on review of initial submissions.
- Simulated Interviews: Discussions will be held with key personnel to assess their ability to respond to potential SEC inquiries.
- Compliance Review: Evaluation of the firm’s adherence to SEC regulations, including disclosures, maintenance of required records, employee supervision, and trading practices, when applicable.
- Expert Feedback: Detailed feedback, which may be oral or written, regarding the firm’s performance during the mock exam as well as recommendations for improvements.
