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Monday, July 30, 2018

Compliance Training - Video Library (RIA Review)

By Cory Roberson, Principal at FIN Compliance and FIN Lancer

July 30, 2018.  To advance the customization of advisory compliance programs, we launched a training video series as a part of our regulatory management system at RIA Review.  RIA Review is a documentation-based solution to help boutique investment advisors to maintain an internal compliance review program.

Our Premium and Premium Plus users will have access to our recorded webinar library that contains insight on compliance topics and regulations issued by the: Securities & Exchange Commission (“SEC”), Office of Compliance Inspections & Examinations, Division of Investment Management, FINRA, state securities agencies, and the North American Securities Administrators Association (NASAA).

With no surprise, the securities compliance industry contains a broad spectrum of rules and regulations.  As such, RIA Review focuses on training topics that are applicable to the boutique investment advisory and/or hybrid RIA/broker-dealer space*.  

*SEC Rule 206(4)-7, state rules, FINRA Rule 3010, 3120
**SEC Rule 203(a)-2(e)

With RIA Review, our goal is for firms to structure a methodical process for:

Conducting a review of policies to comply with SEC, FINRA, and similar state provisions, Managing its periodic tasks in alignment with regulatory filing systems, risk alerts, and policy guidance, Utilizing checklists to break down a review into manageable steps, and/or Creating a schedule to generate documentation for audit prep purposes.   

Our library delves into topics such as the following:

Examination and Audit Prep Processes

In terms of SEC-Advisor Examination prep, our material looks into an actual audit documentation request process.  Similarly, as with our California Advisor Examination prep video, our training moves its lens onto the California Department of Business Oversight process of preparing for an audit.

Forensic Reviews of trading and more

A Best Execution Review video outlines practical steps for firms to perform an assessment of its transactional quality reports.  Advisors should note that Rule 605/606 (transactional quality) reports are available through the firm’s brokerage house that processes client trades.  Moreover, our Robo-Advisory Review video outlines the process for firms who provide advice (or receive services) through an algorithmic trading platform via the internet (ref. Rule 203(a)-2(e) “Internet Investment Advisors”). 

Our Policies and Procedures review instructions includes tips for using our online Review Center, which is designed for breaking down the firm’s compliance program into a: Monthly, Quarterly, Annual, or Ongoing series of checks.  In addition, there is a series of checklists for premium/premium plus users to tailor its reviews of specific policies.     

Ongoing Functions

An Advertising & Compliance video evaluates common discrepancies of marketing materials from more than 1500 firms reviewed by the SEC Office of Compliance Inspections & Examinations (“OCIE”).  (ref. “touting initiative, third-party accolades, use of professional designations).

Post Registration & Annual fees training discusses common firm client/regulatory deliverables, documentation, forms, and annual dues applicable for a registered advisory firm.

Adding or Updating a Rep discusses the process for: (1) Adding, (2) Deleting, and/or (3) Updating information for an investment advisor representative (IAR) filing.  Disclosure documents may include a: U-4, U-5 and/or ADV filing.

Hiring A Solicitors and more videos will be available to Premium and Premium Plus Users of RIA Review.

Compliance Management Services - starting at $995 & up:
Free Version (free/limited) – basic resources to get started
Premium Version ($995/1-yr) – for state registrants not required for perform annual review
Premium Plus Version ($1195/1-yr) * - for SEC and state registrants required to do annual review

Contact Us for special offers and/or consulting assistance: 
Email:, Phone: 650-305-2688 or Website:

Win of the Month:  When a documentation trail can save you from examiner fines.

Examiner – accused client of failing to adhere to registration statute—levied a heavy fine/censure
Cory - We worked to produce documentation trail to prove efforts to comply.
Attorney – Helped to advocate our case
Result – Examiners waived a fine and censure. No DRP required


Making your own documentation trail for auditors

Three suggestions include:

Use an electronic database or client relationship management system (CRM). Advisors should consider attaching correspondence to its database to provide a system for documentation.  

Take notes following a client meeting.  Firms should consider placing notes of communications following a review meeting for documents such as (1) Brokerage agreements, (2) Advisory Contracts, (3) Client objectives, and (4) all other meeting-related information. (reminder for files in electronic storage format). SEC Rule 204-2, 17a-3, 17a-4, and similar state rules.

Save Email Records.  Firms should maintain a record of email communications with clients into its directory/database/CRM.  SEC Rule 204-2 or Securities Exchange Act Rule 17a-3 requires the storage and monitoring of electronic communication for certain firms (e.g. broker-dealers).   There are several email-compliant solutions available in the marketplace.

More practices----Sign up for our Compliance webinars on RIA Review.

Other Regulatory Webinars

We will be announcing public regulatory webinars that will feature service providers in the FinTech, RegTech, Crypto and Blockchain communities.  Stay tuned for announcements as we prepare the launch of an upcoming platform. 

Compliance and Business Management

FIN Compliance ( 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:


FIN Missions ( 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.

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