In addition to remaining available for ongoing consultations and the “hand-holding” that our small to mid-size RIA clients rely upon, Compliance-Minded proudly offers the services listed below.
ANNUAL RENEWALS/UPDATING
Compliance-Minded assists its clients with the annual renewal process, which runs from November through the first week of January. Areas covered include:
Determining that registrations/notice filings are made properly in accordance with each state’s requirements
Assistance with preparing and filing amendments to Part 1 of Form ADV, as necessary
Delivery of preliminary and final renewal statements
Notification of all required fees and subsequent monitoring of posting status
For firms with a December fiscal year-end, we begin the annual updating process in early January. Areas covered include:
Consultation and document reviews, as necessary, to help clients understand their disclosure obligations in accordance with applicable laws & rules and the instructions to Form ADV
Assistance with preparing and filing amendments to Form ADV, Parts 1 & 2A and 2B Supplements
Notification and monitoring of fees
Document reviews and correspondence with state(s) to satisfy additional financials-related annual updating requirements for state-registered advisers, as applicable
ANNUAL REVIEWS/MOCK AUDITS
Under Rule 206(4)-7, SEC-registered advisers are required to annually test the effectiveness of their compliance programs. Through extensive data gathering, analysis, testing, interviews, and a robust reporting process, Compliance-Minded not only seeks to assist firms in detecting and remediating known rule violations but also to provide meaningful controls and best practices in an effort to avoid future issues. Reviews and sample testing generally encompass the adviser’s Code of Ethics (COE), Policies & Procedures (P&P), management agreements, Form ADV, Privacy Notice, Business Continuity Plan, Risk Assessment, client files, and other areas determined to be pertinent by CMLLC and/or requested by the client. Importantly, this service does not end with the report and our support remains available on an ongoing basis for clients with ongoing engagements. This support includes consultation and assistance with implementation of the recommendations from our annual review report, which include but are not limited to draft revisions to COE/P&P, Form ADV, Form CRS, Form U4/U5, management agreements, and other firm documents.
We also offer the above through our project-based Mock Audit service, which requires no ongoing commitment.
CRD/IARD SUPPORT
In addition to annual renewal and updating filings, Compliance-Minded assists clients year-round with required regulatory filings through the CRD/IARD system, including:
ADV 1
ADV 2A & 2B Supplements
Form CRS
Forms U4 & U5
ADV-W
Regulatory Examination Support:
From exam preparedness to assistance with deficiency response letters, we are here to help. Areas we assist State and SEC-registered firms with during regulatory exams typically include:
Consultation on what to expect during an exam and how firm personnel should conduct themselves throughout the process
Providing clarity when specific request list items may be difficult to understand
Help in determining and implementing remedial actions*
Assistance with drafting deficiency response letters*
State/SEC Registration:
Whether you are a new firm looking to register for the first time or an existing RIA looking to switch from State to SEC registration or vice versa, Compliance-Minded will assist your firm throughout the process.**
This process typically includes:
Assistance in setting up IARD access
Correspondence/Communications with regulatory staff, as needed
Creating/Revising Form ADV disclosures; filing through IARD
Creating/Revising Form(s) U4; filing through CRD
Creating/Revising Code of Ethics and Policies & Procedures (SEC advisers)
Creating/Revising management agreement(s)
Ongoing registration status monitoring and consultations with client, as needed
*Compliance-Minded, LLC and its affiliated persons provide general information only and not legal advice. Clients are instructed to engage qualified legal counsel in response to regulatory examinations resulting in significant rule/law violations and/or enforcement proceedings. Clients are solely responsible for all fees associated with legal services, which are separate from those charged by Compliance-Minded.
**State/SEC Registration services do not include entity-related assistance or advice. While we are confident in our ability to assist firms with registration functions, Compliance-Minded, LLC makes no guarantees or warranties regarding a firm’s ability to successfully register with any jurisdiction.