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Year-End Compliance Check

Has your firm has met its compliance obligations for the year? December is typically a busy month for Registered Investment Advisers (“RIAs”) to wrap up priorities and plan for the upcoming year. As a result, we thought the checklist below might be helpful to confirm that you have addressed your compliance obligations for the year.

year end compliance checklist

Year-End Checklist

  • Organization charts are up-to-date
  • Annual regulatory filings have been completed, such as:
    • Form ADV Annual Amendments have been completed
    • Form PF
    • SEC Form D
    • Schedule 13G/D and Section 16 Filings
    • Form 13F
    • Form 13H
    • CFTC/NFA Certifications
    • Form SLT
  • Registration information is current, accurate and complete
    • Terminations – making sure Form U5s were filed
    • New hires – making sure Form U4s were filed
    • Quality Review – checking for common mistakes and omissions:
      • Updates to residential or employment history
      • Disclosure of outside business activities
      • Reporting of any disciplinary actions that took place or are pending
  • Websites
    • Making sure contact information, personnel lists and biographies, and other information listed are current
    • Checking disclosures and legal notices
    • Removing stale information
  • Records
    • Confirm retention of all required books and records
  • Compliance Policies and Manuals
    • Documenting annual review of the adequacy and effectiveness (including implementation) of your compliance policies and procedures within the previous 12 months
    • Confirming any required annual acknowledgements by certain or all employees (check your compliance manual/policies) are completed
    • Maintaining Code of Ethics including making any changes needed considering business and regulatory changes
  • Privacy
    • Delivering annual privacy notice (even if there were no changes) to investors
  • Prepare to collect annual holdings reports per your code of ethics
  • Document review and testing of your firm’s business continuity plan
  • Deliver required training
    • Conducting Annual Compliance Training
    • Delivering special training as needed
    • Confirming all required training has been completed and what measures will be taken for non-completion
  • Make sure you have distributed your restricted list (if applicable)
  • Confirm distribution of your insider trading policy
  • Completion of any obligations if your firm has custody of client funds or securities, such as:
    • Holding client funds and securities with a qualified custodian (g., broker-dealers, banks, etc.) if not eligible for an appropriate exception
    • Verifying the custodian is sending at least quarterly account statements to its clients
    • Checking controls through an annual surprise examination by an independent public accountant
  • Other Items – assess your compliance with other possible areas, such as:
    • Foreign Account Tax Compliance Act (“FATCA”).
    • New Issue Status
    • ERISA Status
    • Pay-to-Play and Lobbyist Rules
    • Soft-Dollar Programs
    • Best Execution Practices

The above list is not intended to be a complete list but a summary of key requirements.  If you have questions about your compliance requirements or need help don’t forget that Adherence is available to help. For more information on how we can help, contact Adherence at http://www.adherencellc.com/contact/.

Adherence Compliance Group +1-917-885-2596
220 W. 93rd Street, #8C New York NY 10025