RIA Review - Our Compliance Management Solution

By Cory Roberson, Principal at FIN Compliance and FIN Lancer 

Advisors,

Investment Management Compliance Decoded 

We understand the difficulties that some firms face while interpreting its regulatory blunders within a robust or “automated” compliance management system.  The plethora of rules associated within the greater financial services industry does not help firms to achieve this feat. 

As such, many compliance management vendors may attempt to accommodate advisors by applying the entire financial services industry (FinServ) into a one-size fits all or “aggregated” solution.  With this approach, one can ask if gaining market share through aggregation is really in the clients best interest.

Does an aggregated solution help all firms?

We believe that the one-size fits all approach can pose more problems than it was intended to solve in terms of user functionality, segmentation, and/or staff adoption.  On one hand, aggregation creates an opportunity for larger firms to piece together a significant amount of information onto one platform.  On another, the robust platform can create a series of complex functionalities that makes it difficult for smaller firms to segment requirements towards it specific needs.

There are inherent difficulties with aggregation for many firms.  In the U.S alone, compliance management for investment managers can be segmented by its fee structure (e.g. commission, fee only, performance fee), services (e.g. portfolio management, financial planning, fund manager, consulting), fiduciary status (e.g. ERISA), structured security products (e.g. broker-dealers, robo-advisory platforms), fund products (e.g. hedge fund, mutual fund, ETF’s), securities exemptions (e.g. Reg A, CF, Private placements), transactional reporting obligations (e.g. pre-post trade fund restrictions), geographic locations (State, SEC, abroad), continuing education, and overall firm operations (policies/procedures, cybersecurity, accounting, designations, business activities).  Try fitting all of this into one platform without problems.

Compliance requirements can vary from firm to firm.  For example, compliance management for a State-registered fee-only firm that offers robo-advisory services can differ greatly from an SEC registered robo-advisory platform that is also under FINRA oversight.   And similarly, a state-registered advisor with U.S. only clients can differ from a state-registered firm with U.S. clients, foreign client reporting, and a private fund.   

Routinely, each regulatory body exercises its own autonomy when it comes to rulemaking over firms within its jurisdiction.  As seen with the DOL Fiduciary Rule debacle, regulators are hard pressed when they attempt to apply its rules across every financial firm in the industry, so the same approach can be made for segmented compliance management solutions. 

With that said, there are some rules enacted by Congress that ultimately apply across all U.S. financial institutions, such as the Gramm-Leach-Bliley Act in terms of client privacy and data sharing. 

At some point, we can hope that pending regulations, such as the U.S. Financial Transparency Act will pave the way for greater regulatory harmony in terms of data sharing, aggregation, and regulatory reporting.  

Solving the problem for compliance

The first line of defense that we suggest is for firms to obtain a general understanding of its regulatory framework.  Advisors can do this by asking questions like What regulatory rules or jurisdictions apply based on our model? 

Next, firms should consider its compliance needs and pick a solution that can fit into its model.  For compliance management purposes, we believe that a segmented approach is best for firms to avoid additional confusion.  We believe that our solution (RIA Review) does this for many boutique advisory firms. 

Our Solution to the madness 

RIA Review is an easy to use digital tool to streamline compliance for boutique Investment Advisory Firms.  We do not promise a compliance solution that can fit (or automate) into every segment of the financial services industry.  Rather, our tool focuses on providing boutique RIA firms with documentation-based solutions that can be tailored within your firm’s business practices to better prepare for an audit. 

Audit fines can start off at several thousand dollars or higher even for infractions, such as gaps in regulatory filings.  Save money and stay on track with a compliance management solution. 

RIA Review also helps firms to understand what rules may or may not apply to their practices.  We’ve focused on this approach while providing consulting support to many of our current software users.  RIA firms can use our solution to boost their compliance program and/or as a supplement to its staffing/consulting support. 

Our Version 2.0 includes a new home page, user-interface dashboard, and enhanced security features.  

                                                                                   

How It Works:

Login to your compliance dashboard.

Check requirements & deadlines.

Customize the firm’s review process.

Print, File, and Store records online.

RIA Review Versions:

Free Version - for those who want to try out a limited version.

Premium Version - for state-registrants with basic reporting needs.

Premium Plus Version - for SEC and State Registrants that also require an annual review.

Premium Hybrid Version – more details coming soon.

Using RIA REVIEW to check 10 common audit pain points:

Common Discrepancies	Functions
Annual Review	Use our Review Center to tailor manual and perform a periodic review for SEC Rule 206(4)-7 and states such as Florida, Washington, and Georgia.
Books/Records	Use our cloud to store books/records in an audit-prep directory.
Contracts	Use templates to update documentation.
Registration/Filings	Use calendar to keep track of filings and/or disclosure documents for records.
Privacy Policy	Use templates or update existing privacy notice.
Fees	Use checklists to test all firm fees for consistency in billing and regulatory reporting.
Custody Rule	Use custody checklist to determine status.
Advertising	Check advertising rules & guidelines.
Supervision	Use code of ethics forms/checklists to monitor access persons and firm requirements.
Financials	See Balance/income sheet sample to view proper accounting formats (GAAP reporting).

Transactional or Documentation-based compliance

While employed in the industry, RIA Review founder Cory Roberson worked on (or trained with) two pre-and post-trade compliance management systems for companies such as Dimensional Fund Advisors and Analytic Investors.  At the time, both systems provided a segmented transactional-based approach for issues specific to trade compliance restrictions and fund portfolio management. 

Since then, he’s observed that most financial industry-based regulatory systems can be articulated into either a: (1) Transactional-based (e.g. trading/restrictions/monitoring) and/or (2) Documentation-based (e.g. audit trail, cloud, report generation) solution. 

RegTech & FinTech Vendors

Compliance reaches every segment of the financial services industry around the globe.  There is a need for more RegTech and segmented solutions.  As such, we are on the lookout for vendors/partners with products that complement our own.   

RegTech Products is a product notification portal featuring RegTech, FinTech and other product offerings for financial services markets, such as: RIA's, Broker-Dealers, Insurance, Blockchain, AML and more.  Contact: cory@riareview.com for more information.

Our History

Consulting: Soft launched in late 2011

Consulting: More than 160+ firm clients served

Software: Soft Launched in late 2016

Software: More than 130+ firm users

Software: Current Version: 2.0

Software: More solutions in the works

For more inquiries, please contact

Cory Roberson

Roberson Ventures Group, LLC.

2950 Buskirk Ave, Suite 300, Walnut Creek, CA 94597

Phone: 650-305-2688

Email: cory@robersonconsults.com or cory@riareview.com

Email Us to schedule a brief session to review needs

Compliance and Business Management

FIN Compliance (FINCompliance.io) is a consortium of compliance services including: RIA Consults-Roberson Consults Group, a compliance consulting firm, RIA Review, a compliance-management software tool (SaaS), B-D Review, a RIA/Broker-Dealer compliance management software tool, and FINLancer is a business management portal featuring:  E-signature tools; Invoicing integration, Vendor Directory, continuity directory*, business client document portal, and more (available by Q3 2019).  Access all services on one site: FINCompliance.io.

Impact

FIN Missions (FINmissions.com) provides business support group sessions for other entrepreneurs.  In addition, Cory has volunteered for more than fifteen youth programs in locations such as like S. Korea, China, S. Africa, Thailand, and India.

Our Privacy Policy Disclosures

Firms can review our privacy policy for our use of client data.  We may use/share data with our vendors/affiliates only in connection with services provided to your firm.  EU Residents/GDPR Compliance: You can choose to opt-in or opt-out of receiving future notifications at any time.  An Opt-Out is located in footer section of our notifications.  We have provided a copy of our privacy notices below. 

Privacy Policy - https://fincompliance.io/PrivacyPolicy