Tailored Compliance Reviews

Our tailored compliance reviews allow you to select targeted areas in which you need assistance and leverage the expertise of Cordium-TwineCordium’s professional staff.

We will put together a customized project based upon your needs and work to help meet your specific compliance obligations.

The scope of a tailored review will be determined in collaboration with each client, but will typically include one or more of the following target areas:

ADV Assistance

Assistance updating your Form ADV 1 and 2

Best Execution Review and Infrastructure Development

  • Evaluate what is presently being done
  • How often are reviews being completed?
  • How are reviews being documented?

Employee Code of Ethics Review

  • Evaluate your firms’ requirements
  • Is the firm subject to Rule 204A-1?
  • Are there other stated requirements?

Perform a critical review of employee files to determine:

  • If all pre-clearance requirements have been met
  • If timing requirements have been met
  • If proper content requirements have been met
  • If all the proper documentation is in place

Hold a focused training session for employees regarding their personal securities reporting obligations

AML Program Review

  • Review AML policies and procedures
  • Forensic testing of investors/clients against AML watch lists
  • Hold focused AML training for certain staff members

Trade Allocation Review

  • Review trade allocation system and output
  • Assist with developing trade allocation best practices
  • Forensic testing of trade allocations

Marketing Materials Review

Perform a compliance review of certain marketing materials (i.e. DDQ, PPT presentations, website, etc.) to look for the following:

  • Have the proper disclosures been made? Are the disclosures in various documents consistent?
  • Are more disclosures needed?
  • Are there any Reg D issues?

Hold a focused training session for your staff to cover:

  • Issues related to review of marketing materials
  • Overview of Reg D and what it means for the investor relations team
  • Review of other marketing-related compliance issues such as Clover Capital, etc.