Our Regulatory Compliance Solutions
The complexity of the Investment Advisor's business model and multiple services
offered can influence the cost to design and build-out the advisory practice or
address the unique service the Investment Advisor needs us to perform.
Please contact us if you would like more information
on our services and quote on the costs.
Our regulatory compliance solutions include:
IARD™ Access and E-Bill
Set-up IARD™ entitlement privileges.
Set-up IARD™ entitlement privileges for the Investment Advisory
firm to have a Super Account Administrator to gain access to the IARD™
website and assist with enrolling the firm in E-Bill to process funds
with FINRA.
- IARD™ stands for Investment Advisor Registration Depository.
The IARD™ is an automated electronic paperless filing system for
Investment Advisors to process the Form ADV and Form U-4s with the SEC and State
Regulatory Agencies.
- E-Bill allows firms to authorize electronic payments (ACH transactions)
directly from a firm's checking account to their Flex-Funding and/or Renewal accounts maintained
at FINRA. This service is offered as a convenience, FINRA does not charge for the
use of E-Bill.
Service Includes: Preparing the IARD Entitlement package for the Super Account
Administrator and our Account Administrator access. Beyond these required forms
there will be an additional fee for each Account Administrator the Investment Advisor
wants designated.
Back to Top
Federal / State Registration
Preparation of SEC Form ADV Parts 1A and 1B for State Investment Advisors.
The Form ADV search is a fill-in-the-blank
questionnaire required for all Investment Advisors to prepare and submit to the
SEC and/or State Regulatory Agencies. The
Form ADV provides regulators with valuable information about who the Investment
Advisor is and the types of advisory services that will be offered in a "check the
box" format.
Service Includes: Preparation of the necessary registration documents with
the State Regulatory Agency where the Investment Advisor maintains their principal
place of business, or if the Investment Advisor qualifies for federal registration,
the SEC registration and state "Notice" filing. There will be additional fees for
each additional state registration or "Notice" filing.
Back to Top
Disclosure Brochure Design
Form ADV Part 2
The Form ADV Part 2A: Firm Brochure requires a plain-English, narrative description of the Investment Advisor's business practices, fees, conflicts of interest, and disciplinary information.
The Disclosure Brochure is the Investment Advisor's most important compliance piece. It is from this document a client or prospective client learns about the Investment Advisor, the services offered, the cost of those services, and any conflicts of interests. If a client or prospective client is unable to make an informed decision about the Investment Advisor, then the Investment Advisor would be considered in violation of the SEC's Antifraud Provisions.
Design of the Disclosure Brochure is created in Microsoft Word, and is made not only to be a compliance piece but a marketing document as well. We can include with the design the Investment Advisor's logo, mission statement, and other unique information the Investment Advisor wants included.
Services Include: Preparation of a Disclosure Brochure includes up to twelve
(12) hours of consultation and interviews if necessary to complete the document.
Back to Top
Prepare a Form U-4 for an Investment Advisor Representative.
The Form U-4 is a fill-in-the-blank questionnaire required for all Investment
Advisor Representatives to prepare and submit to the State Regulatory
Agencies through the IARD. The Form U-4 provides regulators with personal information about who the
Investment Advisor Representative is whether they have any disciplinary history
that would disqualify them from working in this industry.
Services Include: Gathering information from the individual whom Investment
Advisor wants to license as an Investment Advisor Representative and file the Form
U-4 through the IARD™
with the requested State Regulatory Agency. There could be additional cost if the
Investment Advisor Representative has reportable disciplinary actions requiring
the preparation of Disclosure Reporting Pages (DRPs).
Back to Top
Annual Compliance Agreement
The Annual Compliance Agreement provides regulatory compliance assistance for a calendar year.
The Annual Compliance Agreements we offer are packaged to provide Investment Advisors the desired level of regulatory compliance assistance for a fixed fee. By packaging our services, the Investment Advisor benefits from an overall reduced cost while ensures continued ongoing support and assistance. However, none of our Agreements are all-inclusive; there will be additional fees for services should the Investment Advisor exceed the allotted time available in the Agreement or if the service requested has not been included in the Agreement.
Services Include: Telephone consultations, amendments to the
Form ADV on the IARD™, updates to the Investment
Advisor's Disclosure Brochure, access to eAdvisorBACKOFFICE , assistance with annual renewals,
updates to the Written Policies and Procedures Manual, notices of regulatory deadlines and current events.
Back to Top
Written Policies & Procedures
1940 Act Rule 206(4)-7 requires Investment Advisors implement written policies and
procedures reasonably designed to prevent violations of federal and state
regulations and to designate a chief compliance officer responsible for their administration.
The purpose of the Rule is designed to foster, among other things, improved compliance
by clarifying the compliance obligations of the Investment Advisor and its supervised
persons.
Service Includes: A policies and procedures manual and sample forms such
as: advisory agreements, code of ethics, solicitor's agreements and disclosures,
best execution, privacy policies, internal compliance forms, and several others.
Back to Top
Agreements
Preparation of agreements to work in conjunction with the disclosures made in the
Disclosure Brochure or
ADV Part 2A: Firm Brochure.
Forms include, but are not exclusive to:
- Investment Advisory Agreements
- Financial Planning Agreements
- Solicitation Agreements
- Investment Advisor Representative Agreements
- Privacy Notices
- Code of Ethics
Services Include: Developing the agreement for the Investment Advisor based
on their requested criteria. Includes two (2) hours of consultation to complete
each agreement.
Back to Top
Corporation Registration
Set-up of a corporate or limited liability company registration with the Department
of State or where the Investment Advisor want to set up the entity.
Services Include: Preparing the Articles of Corporation or Organization -
depending on the entity type - and following up with the State to be sure all information
is prepared to their satisfaction.
Back to Top
eAdvisorBOOKKEEPER®
eAdvisorBOOKKEEPER is a bookkeeping service designed to aid Investment
Advisors in maintaining accurate accounting records as required by federal and state
investment advisor rules and regulations.
We are not looking to replace the valuable service the Investment Advisor's accountant
may provide their firm. While the CPA clearly understands the accounting process
and tax regulations, the problem we continue to encounter is the impact of various
advisory regulations on the Investment Advisor's financial recordkeeping requirements
which create regulatory issues not directed to accountancy standards.
eAdvisorBOOKKEEPER is designed to come alongside the CPA offering
a bookkeeping service that provides accurate monthly accounting records compliant
with advisory regulations for reporting.
Services Include: Data entry of all statements the Investment Advisor wants
included in their financial records, preparing monthly balance sheet, profit and
loss, trial balance, and detailed general ledger. Service also includes assisting
with preparing your financial records for reporting to federal and state regulators,
and follow-up should there be compliance issues that arise from such financial record
reports.
This service is tiered based on the number of month transactions.
Back to Top
eAdvisorMOCKAUDIT®
eAdvisorMOCKAUDIT is designed as a pre-emptive strike to avoid a
disastrous real SEC or State Regulatory Agency audit.
A mock audit is a great way to know that the Investment Advisor is up-to-date with
its processes and required documentation before it's too late. eAdvisorMOCKAUDIT
can help the Investment Advisor identify potential problem areas and corrective
measures before an official audit takes place.
Benefits:
- Determine the likely results in advance of an SEC or State Regulatory Agency
audit.
- Identify areas of improvement to mitigate the impact of a future SEC or State
Regulatory Agency audit and improve overall regulatory compliance.
- Provide important feedback and support for any "self disclosure" decisions
the Investment Advisor may be contemplating.
Services Include: eAdvisorMOCKAUDIT is a mock audit that
simulates an actual SEC or State Regulatory Agency audit, including the methodology
and procedures. We will review all the data and materials requested in an audit
and conduct an evaluation similar to that condnnucted by the SEC and/or State Regulatory
Agency. The results of the audit analysis will reveal areas of adverse impact and
under-representative.
Our work will take place off and onsite to include the following:
- Review of all written disclosures: Form ADV Parts IA and IB, Part 2A: Firm Brochure,
policies and procedures, and any other disclosure pieces unique to the Investment Advisor.
- Examine employment policies, procedures and practices supporting employment
decisions, such as hiring and terminations.
- Review client files and records that include advisory agreements, privacy
policies, custody practices, other client disclosures, custodial relationships.
- Trading practices: best execution, soft-dollar practices, trade allocation
procedures, principal/agency cross transactions.
- Records retention policies that include electronic storage and e-mail preservation.
Back to Top
eAdvisorWEBHOSTING®
eAdvisorWEBHOSTING will
be offered through a partnership with 352 Inc.
By having your website hosted by eAdvisorWEBHOSTING we will
be able to offer additional services as they come available through this partnership.
One of those services is the ability to automatically capture e-mail communications
to and from clients and drop them in the client record maintained in eAdvisorVAULT.
Services Include: Hosting the Investment Advisors website with Rackspace Hosting®.
Back to Top
Website Design
Website design will be handled by 352 Inc.
A strong Web presence is imperative for every investment advisor, and no one creates sites quite like 352 Inc. With services ranging from Web design and Web programming to Silverlight development, 352 Inc's team of over 50 people can provide specific components or an end-to-end solution. 352 Inc serves clients across the country from offices in Gainesville, Tampa, Jacksonville, Atlanta, and Seattle. Simply complete a proposal request form to take the first step towards a stronger interactive marketing strategy!
Back to Top