We assist investment advisers in the development and maintenance of effective written compliance procedures and internal controls that help prevent abuse, detect and mitigate conflicts of interest, reduce client risk and maintain compliance with client protocols and regulatory requirements. This approach helps to define the roles and responsibilities of senior management and supervisors while promoting successful business practices. To accomplish this, our consulting and support services may include:
- Creation, review or enhancement of your written compliance manual
- Development or review of your Code of Ethics, including personal trading processes, mistreatment of material nonpublic information, and advice on internal trading surveillance programs
- Employee training on new policies and procedures
- Analysis of portfolio management policies and procedures, including oversight of trading activities, allocation of mixed use items for soft dollar arrangements, assessment of investment opportunities and consistency with investor goals, disclosure of best execution practices and review of best execution processes and compliance with SEC recordkeeping requirements
- Evaluation and implementation of recordkeeping and document retention policies
- Review and assessment of privacy policies and procedures regarding safeguards for protecting confidential client information
- Analysis of the conflict of interest processes, and addressing and mitigating same
- Annual testing of policies, procedures and internal controls, with written assessment upon request