Drafting and Implementing Policies & Procedures

We develop policies and procedures that are customized to the needs of your firm’s business, including your firm’s Code of Ethics. Once policies are established, we can assist with implementation, employee training, and ongoing administration.

Gap Analysis, Mock Examinations & Annual Reviews

As a third party, we provide an objective evaluation of the adequacy of your firm’s compliance program (or a subset thereof). This may be done as a best practice, to prepare for future examinations, or to satisfy regulatory requirements pursuant to Rule 206(4)-7 under the Advisers Act.

In the inevitable event of a regulatory examination, we leverage our experience to ensure the examination, whether state or federal, runs as smoothly as possible. We assist with all areas of the examination, including coaching executives to prepare for interviews with SEC staff, drafting written responses to inquiries, obtaining FOIA protection, and managing document production.

Regulatory Filings

We draft and review regulatory filings. We’re experts with your firm’s primary public-facing disclosure document, the Form ADV, and related filings such as the Form PF, Form CRS, and Brochure, as well as additional filings required under the 1934 Act (ex. 13D, 13F, etc.).

Marketing Review

We serve as your marketing review team, providing constructive comments that mitigate regulatory risk while furthering business interests.

Due Diligence Materials

We review drafts and assist in the completion of due diligence materials that are subject to significant regulatory scrutiny, like RFPs and other due diligence requests.