Checklist of Best Practices
Securities regulators believe that robust policies and procedures can help RIAs avoid deficiencies. This is the basis of what most advisers consider “compliance,” but rather than being simply handed down from on high, these policies and procedures require constant review and, when necessary, revision.
All advisers are required to review and revise their Form ADV at least once a year to ensure that it reflects current and accurate information about their firm and its associated persons.
In addition, the North American Securities Administrators Association (NASAA) recommends the following best practices as instrumental in developing and maintaining effective policies and procedures:
* How’s about reviewing and update all client contracts
* Need to create and maintain all required books and records, including financial documentation
* The Cloud maybe? Back up electronic data and take steps to protect records as an offsite location.
* Photocopy, or scan and document any instances where checks were forwarded
* Common sense, but you need to create and maintain client profiles
* Draft a customized written compliance & supervisory procedures manual, (YES, this also is including a business continuity plan)
* Maintain accurate financial statements and purchase a surety bond if required (Errors and Omissions)
* Calculate mgmt fees accurately and in accordance with clients’ advisory contracts and the firm’s Form ADV
* Implement appropriate custody safeguards if they apply (Checking firewalls for clients and your protection).
* Outside vendors? Please review all solicitor agreements, disclosure documents, and your delivery process
* Review all advertisements, including website and performance advertising, for accuracy and to ensure that no content is false or misleading. This is classis Series 65 stuff you really should be aware of.