Throughout the world, investors and businesses alike are voicing growing concerns over social issues such as diversity and climate change in the workplace culture. Despite that Wall Street firms are chiefly concerned with profits, many of their top executives understand that environmental, social and governance (“ESG”) issues present real financial risks. As a result, many public corporations are now focused on ESG issues.
Investor demand for investment products and financial services that incorporate ESG factors has steadily increased in recent years. In response, many investment advisers have begun to offer ESG investment options, including registered investment companies and pooled investment vehicles, e.g., private funds (collectively, “funds”), and separately managed accounts. The SEC has shown a particular interest in the accuracy and adequacy of disclosures provided by registered investment advisers offering clients new types of emerging investment strategies, such as strategies focused on sustainable and responsible investing, which incorporate [ESG] criteria.
Compliance Advisers can assist investment advisers who are offering these new types of ESG investment strategies to prepare proper, accurate disclosures for their clients. Call us today at (303) 795-0400 or email us at firstname.lastname@example.org to request a preliminary consultation regarding ESG Investing Disclosures.
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.
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.
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