Our compliance planning services are designed for advisers that are seeking compliance infrastructure development.

Our project team will help you build out your compliance program by working with you to develop detailed compliance policies, procedures and practical guidelines. We will also include compliance training for your employees with respect to the newly developed procedures. If needed, our team can also assist you through the SEC registration process (from opening an IARD account through the preparation of your Form ADV).

The scope of a typical project will be determined in collaboration with each client, but may include:

Creation of procedures and actual practices related to:

• Record-keeping
• Form ADV disclosure, delivery and updates
• Code of ethics / personal securities trading
• Annual compliance review
• Review of fiduciary obligations
• Custody
• Insider trading
• Money movement controls
• Proxy voting
• General employee responsibilities
• Soft dollar usage
• Privacy policies
• Aggregation/allocation practices
• Email retention and review
• Best execution review process
• Marketing materials
• Public website use and Reg D issues

Ensuring that there is consistency among disclosure documents

SEC registration assistance (if applicable)

Opening an IARD account

Preparing drafts of Form ADV Parts 1 and 2

Assistance in the actual filing of the Form ADV Part 1 and Part 2A

In addition, the project team will help you:

• Develop a formal compliance manual and written policies and procedures
• Develop a detailed compliance calendar that is unique to your business
• Develop and implement a compliance training program for your employees