Home / Operate
Compliance programs that match how the firm actually runs
We build, test and support compliance programs for investment advisers and broker-dealers, working alongside the firm's chief compliance officer and counsel, and writing every program around how the firm actually operates.
ForSEC and state registered advisers, exempt reporting advisers and broker-dealers
Working withYour chief compliance officer and your counsel
EngagementsProgram builds, annual reviews, exam readiness and ongoing support
Investment advisers
Registered and exempt reporting advisers to hedge funds and private funds.
| Area | What the work covers |
|---|---|
| Compliance program | Policies and procedures under Rule 206(4)-7, written for the firm's actual strategy, operation and service providers. |
| Annual review | The annual review with testing, findings, a report to management and an annual compliance calendar built for the firm. |
| Code of ethics | Personal trading, holdings and transaction reporting, preclearance and the monitoring that goes with it under Rule 204A-1. |
| Marketing | Review of pitch books, performance presentations and investor communications under the marketing rule. |
| Filings support | Form ADV, Form PF, Form 13F, Form D and state notice filings, coordinated with counsel, plus transitions between state and SEC registration. |
| Trading compliance | Best execution review, trade allocation and error policies, restricted lists and material nonpublic information controls. |
| Cybersecurity and privacy | Regulation S-P procedures, incident response, vendor oversight and access controls. |
| Training | Annual and new hire compliance training built around the firm's own policies and real examples. |
Broker-dealers
Institutional, agency and introducing firms, new and established.
| Area | What the work covers |
|---|---|
| Written supervisory procedures | Procedures under Rule 3110 that match the firm's business lines, supervisory structure and systems, with clear owners for each review. |
| Annual testing and certification | Supervisory control testing and the report under Rule 3120, and support for the CEO certification process under Rule 3130. |
| Anti-money laundering | The AML program and customer identification procedures under Rule 3310, suspicious activity review workflow and independent testing. |
| Surveillance design | Trade and communications surveillance that fits the business, with tuned parameters and an alert workflow that leaves a record. |
| Communications | Review and approval processes for correspondence, institutional and retail communications under Rule 2210. |
| Books and records | Electronic communications archiving, retention schedules and the inventory of records under SEC Rules 17a-3 and 17a-4. |
| Branch and remote supervision | Inspection programs for branch offices and residential supervisory locations, and the documentation each inspection needs. |
| Membership changes | Continuing membership applications under Rule 1017 for new business lines, ownership changes and other material changes. |
Exams and diligence
Mock exams
A review run the way SEC and FINRA examiners run theirs, with document requests, interviews and a written report of what an examiner would likely find.
Exam support
Organizing the response to a document request, preparing the people being interviewed and tracking every commitment made to the examiners.
Deficiency remediation
Turning exam findings into fixed processes, updated procedures and evidence that the fix is working.
Due diligence questionnaires
Consistent, accurate answers for allocators, primes and counterparties, backed by the documents they will ask for next.
Ways to engage
| Engagement | What it includes |
|---|---|
| Program build | A new or rebuilt compliance program for a launch, a registration change or a new business line. |
| Annual review and testing | The adviser annual review or broker-dealer supervisory control testing, with a written report. |
| Exam readiness | A mock exam, remediation of what it finds, and support through the real one. |
| Ongoing support | A retainer that gives your compliance officer a second set of hands for filings, reviews, testing and questions as they come up. |
Working with your team
- Your compliance officerYour CCO and supervisory principals stay in their roles. We give them a second set of hands for design, testing, filings and exams.
- Your counselLegal questions go to your lawyers. We make sure the procedures match what the operation does and what counsel has advised.
- Your auditorFinancial statement audits stay with your independent auditor. We help the operation produce what the audit needs.
- Your vendorsSurveillance, archiving and compliance platforms are reviewed for fit and configured to the business rather than replaced by default.