Our tailored compliance reviews allow you to select targeted areas in which you need assistance and leverage the expertise of Cordium’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:
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.