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Monday, November 9, 2020

SEC Risk Alert - Supervision, Compliance, and Multi-Office Branch Exams

November 9, 2020. The Securities and Exchange Commission ("SEC") Office of compliance inspections and examinations issued its audit results of nearly 40 firms with multiple branch offices located throughout the United States.  View alert here.

Exam Focus/issues:

Compliance programs/supervision: 
During the audit, SEC examiners discovered issues related to: (1) firm procedures for custody, (2) advisor processes for disclosing fees, (3) overcharging clients, (4) non-compliance with advertising rules, and (4) inconsistencies with Code of ethics reporting. 

Investment Advice: In addition, OCIE staff noted deficiencies in: (1) advisor client recommendations; (2) mutual fund share class disclosures; (3) setup of wrap fee programs, and (4) reporting of firm conflicts of interests.


       FIN Compliance Products and Services 

RIA Registration Services:  New/existing firms.
RIA Compliance Consulting:  Ongoing/annual services.
Compliance Management System: Compliance portal for resources, forms, and checklists.
Business Management System: Business portal for file sharing, e-contracts, and more. 
Advisor Continuity/Solicitor Support:  RIA Succession/continuity/solicitor services.
Business/Referral Network: Inquire about advertising/consulting projects. 

Our Approach

Compliance Management - We work with companies who are seeking to manage their compliance obligations - serving more than 175+ firms with compliance services and a system of SEC and state regulatory resources located on one site.

Business Management - We provide firms with task-management processes and a business directory to connect with other firms for continuity, succession planning, partnerships, and deal flow.  Also, we have a small network of referral partners for practice management, operations workflows, accounting, and website design.

Needs Analysis Workflow - We work with firms in determining their compliance management priorities.  During/after a need’s analysis, we provide firms with compliance/business service options to address those needs and will provide firms with sample workflows for task delegation purposes.

Audit Preparation - We help firms in addressing compliance deficiencies while acting as an intermediary for resolving issues between (you) the advisor and regulators/examiners. We can also assist firms in audit prep measures.

Regulatory Changes - We research regulatory updates from state, SEC, and/or FINRA jurisdictions. We’re here to help as some rules/regulations may be amended over time.

About FIN Compliance 

FIN Compliance  (FinCompliance.iois a consortium of compliance, consulting, and business management solutions designed to help boutique investment firms to structure, maintain, and develop their internal regulatory review programs.  

Our product line consists of:  RIA Consults-Roberson Consults Group, a compliance consulting firm, RIA Review, a compliance-management system, B-D Review, a Hybrid-management system (est. in 2020)*, and FIN Lancer, a Business/Task Management system. 

Impact/Missions - see website

Contact:  Cory Roberson -  

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