Category Archives: Investment Adviser

Form CRS Filing Deadline June 30

Contact us for a quote to prepare your Form CRS

In June 2019, the SEC adopted requirements (SEC Release 34-86032) for registered investment advisers, broker-dealers, and dual-registrants that do business with retail investors to file Form CRS (customer relationship summary). Form CRS is intended to inform retail investors about:

  • The types of client/customer relationships and services the firm offers;
  • Fees, costs, conflicts of interest, and required standard of conduct associated with those relationships and services;
  • Whether the firm and its financial professionals currently have reportable legal or disciplinary history;
  • How to obtain additional information about the firm.

The deadline for firms to be compliant with Form CRS is June 30, 2020.

IA’s: 2019 Rule 206(4)-7 Annual Review Due NOW

SEC Rule 206(4)-7 requires advisers to conduct an Annual Review to determine whether the firm’s policies & procedures are reasonably designed and implemented to prevent violation of federal securities laws (adequacy testing) and are effectively operating to prevent compliance problems, identify problems that occur and promptly correct those issues – achieving the goals as intended (effectiveness testing).

There are several advantages to engaging Compliance Advisers to conduct your Annual Review–

  • Capitalize on Our Many Years of Experience Conducting Annual Reviews
  • Achieve Maximum Objectivity to ensure that Deficiencies are Fully Identified and Corrected
  • Obtain Broader Insights into the Effectiveness of your Policies and Procedures
  • Preserve precious time and resources for other compliance matters
  • Cost Effective Means to Meeting this Regulatory Requirement

Contact us or Request a Customized Quote today  to conduct your firm’s 206(4)-7 Annual Review.

Preparing for the New Form ADV Amendments

By Karen A Steighner, MBA 

Compliance Advisers, Inc. 

October 2017 – In August 2016, the SEC adopted amendments to Form ADV that became effective on October 1, 2017. This means that most investment advisers will likely need to address the requirements of these amendments for the first time when they file their annual updating amendment in 1Q 2018. However, registered investment advisory firms are encouraged to consider how these amendments impact their specific business well in advance of the filing deadline.

The Amendments are intended to improve the depth and quality of information that clients receive about their investment advisory firm by modifying Part 1A of Form ADV in three areas: 1) revisions to fill certain data gaps and to enhance current reporting requirements; 2) amendments to incorporate “umbrella registration” for private fund advisers; and, 3) clarifying, technical and other amendments to existing items and instructions.   Let’s be clear though—the new information required by these amendments will also benefit the SEC by filling data gaps and facilitating their risk monitoring initiatives. Here is a summary of the new amendments:

Separately Managed Accounts. While detailed information about pooled investment vehicles has historically been collected on Form ADV Part IA, specific information regarding separately managed Continue reading Preparing for the New Form ADV Amendments