Case Studies
Who: A Texas-based solo practitioner registered with the State Securities Board. The firm provides investment advisory, consulting, and financial planning services.
Problem: As a newly registered firm, the advisor needed additional insight with applying the state rules to its practice.
Solution: On an ongoing basis, we provide a solution for the firm to customize its compliance procedures, apply disclosures, and update documentation based on firm changes. We also assist the firm with its periodic filings.
Topics Covered:
Who: A California-based advisory firm (>$110MM AUM) with a small staff that is registered with the Securities and Exchange Commission (“SEC”). The firm provides investment advisory, financial planning, third-party referrals, and tax services to a growing audience.
Problem: The partner is juggling multiple roles. Along with multiple firm changes, the advisor needs assistance with its compliance duties in relation to the SEC’s annual review requirements of firm policies and procedures (ref. Rule 206(4)-7).
Solution: On an ongoing basis, we provide a solution with assistance for the firm to customize its compliance procedures, apply disclosures, review procedures, and update documentation based on firm changes. We also assist the firm with its periodic filings
Topics Covered:
Who: A California-based advisory firm (>$70MM AUM) with a small staff that is registered with the Department of Financial Protection & Innovation. The firm, which maintains foreign business activities, provides investment advisory, financial planning, consulting, and tax services for residents in the United States and for expats abroad.
Problem: The partner needed assistance with training an operations staff member to update the firm’s compliance policies and procedures.
Solution: In an action plan review, we assisted the firm with understanding which policies apply to the firm along with a series of recommendations for the practice.
Topics Covered:
Who: A Pennsylvania-based advisory firm (>$30MM AUM) with a small staff that is registered with the Pennsylvania Department of Banking and Securities. The firm provides investment advisory, consulting, and financial planning services.
Problem: Operations staff member needs ongoing assistance with updating the firm’s compliance policies and procedures.
Solution: On an ongoing basis, we provide answers to support the firm in customizing its compliance procedures, disclosures, and update documentation based on firm changes. We also assist the firm with its periodic filings.
Topics Covered:
Who: A California-based robo-advisory/broker-dealer firm with a small staff that is registered with the Securities and Exchange Commission (“SEC”) and the Financial Industry Regulatory Authority (“FINRA”). The firm provides internet only services and maintains some business activities abroad.
Problem: The partner is onboarding an operations staff, which includes two registered representatives, to manage the firm’s compliance duties for both its jurisdictions.
Solution: We provide answers to support the firm in customizing its compliance duties, disclosures, and updating documentation based on firm changes. We also assist the firm with its periodic filings.
Topics Covered:
Who: A Florida-based advisory firm (>$400MM AUM) that is registered with the Securities and Exchange Commission (“SEC”). The firm provides portfolio management and pension consulting services.
Problem: The firm needs an online compliance system for resources.
Solution: We provide access to our online compliance-subscription based system.
Topics Covered:
What is the deficiency?
How can you fix this?
How can we help with consulting and/or technology?
Solution: Contact us for tips and workflows
Inconsistencies between ADV Part 1 & 2 updates
Solution: Review ADV and/or contact us
Inaccurate client Suitability Information
Solution: Update client suitability information and create procedures to review allocations
Fee Formula is not clearly stated
Solution: Update contracts with accurate fee schedule.
No procedures to protect vulnerable citizens
Solution: Create procedures for monitoring seniors/vulnerable citizens
Untrue statements
Solution: Review Advertising periodically
Charges don’t match ADV or contract
Solution: Review fee charges
No policy or procedures
Solution: Create procedures for vulnerable citizens
Improper invoice format for direct fee deductions/custody safeguarding
Solution: Update invoicing format
Inadequate net worth (advisors’ w/ discretion)
Solution: Move funds into a business account
No evidence of annual delivery of privacy policy
Solution: Create procedures and implement a system for annual delivery
Sending Notifications, automated processes for scheduled tasks, and document storage.
Our Solution:
Task Notifications (CRM or Email) - Non-Zapier route – use email integration plugin and manual schedule tasks directly to apps for automation.
Task Notification/Automations (on FIN Compliance) - Non-Zapier route – use our email automation feature to receive task list monthly or quarterly.
Tasks/Automation (CRM or Email) - Zapier Route - transfer suggested or custom tasks to apps.
Document Storage – continue using third party (cloud) and/or we have a file storage capability for compliance purposes.
Code of Ethics Reporting for staff
Sending annual attestation forms and other questionnaires to staff.
Sending automated requests for quarterly statements for staff trade review.
Sending for staff to submit marketing, correspondence, etc. for CCO review with approval/rejection steps.
Our Solution:
Disclosure Center: Staff Disclosures –
Desktop weblink or mobile access for staff Delivery of Disclosures/Collect Reports
Marketing Approval Requests – to log advertising approval requests.
Pre-Clearance Securities Requests – if you require pre-clearance.
Other Business Activities – for code of ethics reporting
Holdings Reports – for code of ethics reporting of annual or quarterly statement.
Employee Attestations/Certification – for code of ethics reporting
Gifts and Entertainment- for DOL fiduciaries or broker-dealers
Annual/Ongoing disclosure delivery to clients, prospects, and vendors
Our Solution:
Disclosure Center: Public Disclosures –
Desktop weblink or mobile access for delivery of annual disclosures (such as ADV or Privacy notices)
Clients, Prospects, or Vendors may:
Download documents via weblink
Request documents via email
Request documents to be mailed
Audit Logs to maintain for admin recordkeeping
Aggregation of third-party technology reports for compliance recordkeeping
Our Solution:
Third Party Audit Logs on Staff Disclosures portal:
An import feature for turning third party reports into audit logs on our staff disclosure portal.
Alternative to Zapier due to firm, network, or broker-dealer data security restrictions.
Our Solution:
Manual plugins are available to integrate calendar tasks or audit logs directly to or from our systems instead of using Zapier.
Using FIN Compliance and building automations with technology solutions not on Zapier
Our Solution:
We have an API and are open for enterprise partnerships.
