Program Reviews

• The SEC Compliance Program Rule requires each SEC registered investment adviser to review its compliance policies and procedures at least annually to determine its adequacy and the effectiveness of its implementation. The expectations of the SEC as it relates to the annual review process are extensive and include periodic and forensic testing, a dynamic risk assessment process, the impact of new regulations and changes in the business and ongoing compliance issues that arise.
• Our team has developed an annual review program for firms that wish to outsource all, or a part, of the annual review function. We have significant experience in developing compliance systems and conducting regulatory audits for SEC registered investment advisers, both large and small.