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Compliance Review

In: Business and Management

Submitted By dukatron
Words 276
Pages 2
Compliance Program / Annual Procedure Review

Rule 206(4)-7 of the Investment Advisers Act creates a fiduciary responsibility for investment advisers to review annually their policies and procedures to determine their adequacy and the effectiveness of their implementation. As part of this review, all policies, procedures and responsibilities of an adviser must be reviewed, and the findings documented. The review should consider all factors that might suggest a need to revise the policies and procedures including any compliance matters that occurred during the year, any changes in the adviser’s or its affiliates business activities, or changes to applicable regulations. Reviews should be conducted by independent individuals (e.g., the department manager) not immediately responsible for implementation of a particular procedure. An overall review and approval of the adviser’s policies and procedures should be completed by the Chief Compliance Officer and should be submitted to the adviser’s Management Committee or Executive Officers for Final Action.

|Procedure | |Summary & |Recommended |Reviewer & | |Completion Date & |
|Reviewed |Findings |Conclusions |Change/Update |Date of Review |Review by CCO |Final Actions |
|Advertising | | | | | | |
|Advisory Agreement | | | | |...

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