Tuesday, December 19, 2017

End of Year Compliance Action Items

End of Year Compliance Action Items

Here are 5 compliance action items to keep in mind as 2017 comes to a close:

1. Renewal Fees

The deadline for the payment of your preliminary renewal fees was yesterday (December 18, 2017). The next deadline to be aware of is December 26, 2017, which is the deadline to submit any registration terminations in jurisdictions where you are no longer required to be registered. Please click here to view our previous Advisor Alert related to the annual renewal process and important deadlines.

2. Annual Compliance Training

If your firm hasn't done so already, now is a good time to conduct a 2017 annual compliance training. It is essential that your firm conducts an annual training for all supervised persons of the firm to establish and reinforce the firm's policies and procedures. Topics should include roles and responsibilities for the CCO and supervised persons, core compliance topics, and industry hot topics.

3. Annual Review and CCO Report

Rule 206(4)-7 of the Investment Advisers Act of 1940 and other state regulations require that Advisors implement (and maintain) a compliance program that is designed to prevent, detect and correct any violations of the securities laws. On an annual basis, the Chief Compliance Officer (“CCO”) is responsible for performing an annual review to determine the adequacy of the compliance program.

SEC Registrants: Details and findings of the annual review are required to be captured and archived in an Annual CCO Report.

4. FINRA Entitlement User Accounts Certification

At the beginning of each year FINRA requires that the Super Account Administrator ("SAA") for your firm validate the users that have access to your filing, billing and related information within 30 days of the notice. Please Note: AdvisorAssist will provide you with reminders and instructions to guide you through the process.

5. ADV Amendment

Advisors are required to file an amended Form ADV1 and Form ADV2A within 90 days of their fiscal year end. For those advisors that use December 31, 2017 as their fiscal year end (which is most of you), the deadline to file your amended ADV is March 31, 2018. Please Note:AdvisorAssist will provide you with questionnaires and reminders to guide you through the data gathering process.

As a reminder, on October 1, 2017 the United States Securities and Exchange Commission (the “SEC”) released revisions to the Form ADV 1. Advisors will need to provide additional information for Item 1 - Identifying Information, Item 5 - Information about Your Advisory Business and Item 8 - Participation or Interest in Client Transactions. For additional information on the changes, please click here to view our post on the Form ADV 1 changes.

SEC Registrants: Additional funding to your E-Bill account will be required for your annual ADV amendment. The fee is debited at the time of filing your firm's ADV and is based on the fee schedule below:

Regulatory AUM Annual SEC Amendment Fee
$100M or More $225
$25M to $100M $150
Less than $25M $40

In the meantime, should you have any questions, please contact us at support@advisorassist.com or reach out directly to your compliance consultant.

AdvisorAssist Team


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