Forming a New Registered Investment Adviser
Many firms in the industry are transferring from commission to fee-based business for professional asset
management and financial planning. In order to conduct this type of business, you must be a registered
investment adviser.
For startup firms, CCLS can help register the firm and its personnel so that you can begin managing assets.
Based on an hourly fee engagement, CCLS will formulate the advisory legal and compliance programs based
on your unique business needs. Project time lines will be customized and developed based upon your
service needs:
Please contact us at (619) 278-0020 or (877) 222-4833 for more information.
Changing your Existing Ownership
CCLS helps client firms evaluate legal and compliance risks as you merge, acquire, sell and/or develop new
business segments within your organization. Should you be involved or become affiliated with a broker-dealer,
bank, CPA or law firm, CCLS will evaluate the relationship to develop a comprehensive training for the firm’s
non-participating partners to educate them on the intricacies of doing business in the investment advisory
world.
Investment Adviser Consultation Services
Once your investment advisory firm is established, CCLS’s Investment Adviser Consultation Services offer
legal, compliance and financial accounting solutions to firms and investment advisory professionals through
three steps.
Step 1: Know Our Client – CCLS begins by gathering information on your firm to ensure we thoroughly
understand the adviser’s needs. Together, we assess your goals, growth projections, strengths and risk
management concerns in order to ascertain successful solutions for your business model.
Step 2: Understand Alternatives – CCLS will present alternatives and solutions available to the adviser as
they develop their legal, compliance and financial accounting programs. The investment adviser consulting
services are led by Michelle Jacko and supported by a talented team who have spent their careers in the legal,
compliance and/or financial accounting departments of leading firms. Our consultants understand the
complexities of the marketplace and the challenges investment advisers face. Through our involvement in
speaking engagements, industry groups, article publishing and networking, CCLS stays current on the latest
regulatory and risk management standards throughout the industry.
Step 3: Implementation – Identifying the advisory firm's consultation needs is our top priority. CCLS will help
to implement requirements mandated by the regulators, provide internal control best practice solutions and
customize policies to fit your investment adviser model.
In our initial meeting, Clients will help us to develop a project plan that outlines the priorities and timeline for
completion of all projects. Our Investment Adviser Consultation Services allow you to pay as you go based
on actual time spent on the engaged project. We believe this assists in helping client firms to better anticipate
costs and provides on-going services as you need them for your business. Each package is customized
based on your unique needs. CCLS's Investment Adviser Consultation Services include, among other
things:
regulatory issues and rule promulgation.
*Comprehensive Assistance
CCLS understands that some advisory firms require comprehensive assistance in evaluating its compliance
programs. For those with particular needs, we offer the following solutions for your business.
Many firms in the industry are transferring from commission to fee-based business for professional asset
management and financial planning. In order to conduct this type of business, you must be a registered
investment adviser.
For startup firms, CCLS can help register the firm and its personnel so that you can begin managing assets.
Based on an hourly fee engagement, CCLS will formulate the advisory legal and compliance programs based
on your unique business needs. Project time lines will be customized and developed based upon your
service needs:
- Completion of Forms ADV Part 1 and II
- Review of business developments, potential conflicts of interest identified and business risk
management solutions - Author Schedule H to Form ADV and draft accompanying wrap fee brochure
- Assess and register each person required to be an investment adviser representative based on state
securities registration requirements - Formulate client agreements, client profiles, investment policy statements, account statements, and
other necessary client forms - Author referral and solicitors agreements as necessary
- Review proposed marketing materials to ensure compliance with relevant securities regulations
- Develop written policies and procedures customized to the client firm’s business
- Create Code of Ethics, Privacy Policy (Regulation S-P), Business Continuity Plan, Proxy Voting and Anti-
Money Laundering Programs based on the adviser's business model - Suggest compliance program technology solutions and internal controls
- Provide annual compliance calendar for the adviser to use in testing the efficacy of the firm’s
compliance program - Develop a comprehensive books and recordkeeping process, including identifying roles and
responsibilities for key areas along with retention periods - Provide ongoing consultations and risk assessments as requested
Please contact us at (619) 278-0020 or (877) 222-4833 for more information.
Changing your Existing Ownership
CCLS helps client firms evaluate legal and compliance risks as you merge, acquire, sell and/or develop new
business segments within your organization. Should you be involved or become affiliated with a broker-dealer,
bank, CPA or law firm, CCLS will evaluate the relationship to develop a comprehensive training for the firm’s
non-participating partners to educate them on the intricacies of doing business in the investment advisory
world.
Investment Adviser Consultation Services
Once your investment advisory firm is established, CCLS’s Investment Adviser Consultation Services offer
legal, compliance and financial accounting solutions to firms and investment advisory professionals through
three steps.
Step 1: Know Our Client – CCLS begins by gathering information on your firm to ensure we thoroughly
understand the adviser’s needs. Together, we assess your goals, growth projections, strengths and risk
management concerns in order to ascertain successful solutions for your business model.
Step 2: Understand Alternatives – CCLS will present alternatives and solutions available to the adviser as
they develop their legal, compliance and financial accounting programs. The investment adviser consulting
services are led by Michelle Jacko and supported by a talented team who have spent their careers in the legal,
compliance and/or financial accounting departments of leading firms. Our consultants understand the
complexities of the marketplace and the challenges investment advisers face. Through our involvement in
speaking engagements, industry groups, article publishing and networking, CCLS stays current on the latest
regulatory and risk management standards throughout the industry.
Step 3: Implementation – Identifying the advisory firm's consultation needs is our top priority. CCLS will help
to implement requirements mandated by the regulators, provide internal control best practice solutions and
customize policies to fit your investment adviser model.
In our initial meeting, Clients will help us to develop a project plan that outlines the priorities and timeline for
completion of all projects. Our Investment Adviser Consultation Services allow you to pay as you go based
on actual time spent on the engaged project. We believe this assists in helping client firms to better anticipate
costs and provides on-going services as you need them for your business. Each package is customized
based on your unique needs. CCLS's Investment Adviser Consultation Services include, among other
things:
- Consultation on and risk assessment of all items described in the above section, "Forming a New
Registered Investment Adviser" - Mock SEC examinations* and internal audits*
- Guidance to legal and compliance issues, concerns and questions
- “Plain English” explanation of new or amended SEC and applicable state rules and regulations
- ERISA compliance
- Reviews of all performance advertising, sales literature and request for proposals in conformance with
GIPS and SEC requirements - Soft Dollar Compliance
- Review of best execution and trade allocation procedures
- Wrap-fee program compliance (including due diligence of money managers and program sponsors)*
- Comprehensive interview with appropriate personnel to prepare for SEC and state examinations
- Consultation during regulatory examinations
- Review and comment on proposed responses to state and SEC regulatory inquiries
- Evaluate complex advisory sales practices
- Provide consultation regarding potential partnerships or arrangements with financial professionals
- Review advisory surveillance efforts
- Provide annual review testing of the adviser's compliance program*
regulatory issues and rule promulgation.
*Comprehensive Assistance
CCLS understands that some advisory firms require comprehensive assistance in evaluating its compliance
programs. For those with particular needs, we offer the following solutions for your business.
- Mock SEC / State Examinations – CCLS will focus on all facets of preparing for the examination,
including interviews, books and records requirements and regulatory reporting. - Internal Audits – CCLS will conduct internal audits and review the trade desk, portfolio management,
performance reporting, investment manager agreements, marketing and sales practices and other
internal and compliance controls. - Due Diligence – CCLS will perform, as needed, due diligence of Third-Party Service Providers, Third-
Party Solicitors and Third-Party Managers. This may include, among other things, review of disclosure
documents, compliance efforts, internal controls, regulatory issues, financial stability, performance
and background check. - Annual Compliance Program Review – CCLS will conduct the client firm’s annual compliance
program review. This may include, among other things, interviews with senior management to assess
the “Tone at the Top,” review and testing of the compliance program, assessing the robustness of firm
policies and procedures, documentation of internal controls, granting of exceptions and actions taken
by the client firm throughout the year to address compliance deficiencies. Thereafter, CCLS will provide
a written summary report of the review’s findings to the client.
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Core Compliance & Legal Services, Inc.
Solutions for Today's Business
Solutions for Today's Business
