RIA Review is a user-friendly online compliance and operations management software designed to help boutique investment advisors to structure, to maintain, and to develop their compliance programs.
Our Review Center allows solo-advisors, internal staff, and/or consultants to create a maintenance schedule to update their firm’s policies and procedures as needed.
For Solo-practitioners (CCO’s):
For Staff/Compliance Staff:
Yes, we are in the process of adding capabilities from other service providers. We will consider more in the near future.
All firms should login to the calendar section to access the general overview of annual firm requirements (i.e. to-do list of items to file with regulators and/or send to clients annually).
All firms must first register here: http://www.riareview.com/Account/Register
Note: The calendar is not an exhaustive list of every reporting requirement that may apply to your particular firm. Feel free to contact us for an interpretation of requirements.
As a part of Rule 206(4)-7, SEC-registered investment advisers (under the Investment Advisers Act of 1940) must:
Some states, such as Washington and Florida, require firms to conduct an annual review of their firm’s policies and procedures. Other states recommend firms to conduct an annual review, along with maintaining a compliance manual of firm policies and procedures.
Note: State advisors may refer to the SEC’s annual review guidelines as mentioned above.
As defined by Rule 206(4)-2, of the investment advisors acts, these entities are:
"Independent representative" means a certified public accountant or attorney who: Acts as agent for an advisory client, including in the case of a pooled investment vehicle, for limited partners of a limited partnership, members of a limited liability company, or other beneficial owners of another type of pooled investment vehicle and by law or contract is obliged to act in the best interest of the advisory client or the limited partners, members, or other beneficial owners;
Is engaged by you to act as a gatekeeper for the payment of fees, expenses and capital withdrawals from the pooled investment;
"Qualified custodian" means the following independent institutions or entities that are not affiliated with the adviser by any direct or indirect common control and have not had a material business relationship with the adviser in the previous two years:
A bank or savings association that has deposits insured by the Federal Deposit Insurance Corporation under the Federal Deposit Insurance Act
A licensed broker-dealer holding the client assets in customer accounts;
States firms (most states*):
Business Continuity Planning:
According to Rule 204-2 (books/records) of the investment advisors act (and similar state rules): Firms should test and regularly update their business continuity plan at least once a year.
While drafting a plan to satisfy the SEC’s latest amendment to Rule 204-2 (and similar state rules), advisors should consider the firm’s operational/legal components. In the event of the death/incapacitation of a advisor/owner: (1) who immediately takes over to safeguard assets (operational duties during an emergency), and (2) what legal agreement is in place if the death/incapacitation of an advisor/owner prompts an estate issue* with any heirs of business, regulators, and/or other employees.
Paid software users may use our:
(1) business continuity form to organize vendors and (2) conduct testing.
Advisory/Portfolio Management Fees:
Financial Planning Fees:
Consulting Fees (generally hourly structure):
Note: The following is a general estimate based on research from our compliance consulting partner: RIA Consults – Roberson Consults Group.
ADV Reporting: Item 5
According to Rule 205-3 of the investment advisors act (also applies to state-registrants),
Clients must have:
Pre-2011 clients: Will be grandfather into the "pre-2011" thresholds ($750,000 in assets with firm or $1,500,000 in net worth). Firms can continue to rely on grandfather clauses for these types of clients.
Effective 8/15/2016, threshold limits were increased from $2 million to 2.1 million to factor in inflation.
ADV Reporting: Item 6
Generally, there are four types of agreements to enter into an advisory relationship with client and/or prospect. This is outside of: (1) Brokerage agreements (2) Estate agreements, and/or (3) Subscription documents (for private fund investors)
According to Rule 204-2 (books/records) of the investment advisors act (and similar state rules)
Firms should keep client records