Pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act, dramatic changes are occurring within the industry. As a result of the elimination of the “private adviser” exemption, managers who act as an adviser solely to hedge and private funds with assets of $150 million or more must re-register with the SEC. Furthermore, the SEC increased the threshold for federally registered investment advisers from $25 million to $100 million.

CCLS can help firms to create or amend regulatory filings as well as advisory compliance programs in conformance with the latest regulation requirements.

Forming a New Registered Investment Adviser

Whether you are an advisor to a private fund or wanting your own fee-based business for professional asset management and financial planning,   we can assist in registering you as an investment adviser.
For start-up 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 compliance programs based on your unique business model. Project timelines will be customized and developed based upon your service needs.  CCLS can help you by:

• Drafting and filing forms ADV Part 1 and 2
• Completing all required notice filings
• Assessing business regulatory requirements, new business developments, potential conflicts of interest and risk management considerations
• Licensing and registration of investment adviser  representatives based on individual state securities registration requirements
• Authoring client agreements, client profiles, investment policy statements, account statements, and other necessary client forms
• Drafting referral and solicitors agreements as necessary
• Reviewing proposed marketing materials, including website and performance disclosures to ensure compliance with relevant securities regulations
• Developing written policies and procedures customized to the firm’s
  business
• Developing Codes of Ethics, Privacy Policy (Regulation S-P), Business
  Continuity Plan, Proxy Voting and Anti-Money Laundering Programs
• Suggesting compliance program technology solutions and internal controls
• Providing annual compliance calendar for the adviser to use in testing the
  efficacy of the firm’s compliance program
• Developing a comprehensive books and recordkeeping process, including
  identifying roles and responsibilities for key areas along with retention
  periods
• Providing ongoing consultations and risk assessments as requested

RIA Consulting Services

Once your RIA is formed, CCLS can provide continuing or project based consultation services dependent upon your needs.

CCLS’ Investment Advisory Services include:

• Formation of investment advisory firms (including corporate formations)
• Annual updates and notice filings for Investment Advisory Firms
• Development and review of current compliance program
• Analysis of requisite internal controls and mitigation of known conflicts of interest
• Compliance training to firm personnel
• Outsourcing solutions (such as review of marketing and performance advertising, U-4 filings, annual ADV updates etc.)
• Guidance and assistance with converting from State to SEC Registration
• Analysis on how new and revised regulations affect your firm
• Mentoring the Chief Compliance Officer (CCO)
• Creation of customized compliance calendar for the firm
• Periodic on-site risk management reviews
• Compliance consulting on an “as needed” basis

For more information, contact us at (619) 278-0020