Build a practical, adviser-specific compliance framework designed to support your Chief Compliance Officer (CCO), reflect how your firm actually operates, and stand up to regulatory review.
Registering as an investment adviser is only the beginning. Under SEC Rule 206(4)-7, SEC-registered advisers must adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. Generic manuals often create issues when they do not match the firm’s actual business, personnel, and day-to-day practices.
At Ishimbayev Law Firm, we help RIAs build compliance programs that are tailored to the way the firm actually operates. We work with newly registered advisers, transitioning ERAs, and growing wealth management firms to prepare policies, codes, and related procedures that are legally grounded, practical to administer, and better suited to regulatory review.
Drafting tailored written policies and procedures addressing the areas most relevant to your firm, such as trading, allocation, best execution, custody, books and records, valuation, and vendor oversight where applicable.
Preparing or refining the Rule 204A-1 Code of Ethics, including standards of conduct, personal trading controls, reporting obligations, and related compliance procedures for supervised persons and access persons.
Drafting or refining business continuity, incident response, information security, and related operational policies in a way that reflects the firm’s size, structure, and risk profile.
Establishing review procedures for pitch decks, websites, performance materials, testimonials, endorsements, and related communications in light of the SEC’s Marketing Rule and anti-fraud standards.
We begin by reviewing your firm’s business model—its fee arrangements, asset classes, custody profile, marketing practices, and operational setup—to identify the areas that warrant the most attention.
We prepare the compliance manual, Code of Ethics, and related policies with the goal of matching the documents to the firm’s actual practices rather than relying on generic language that may not fit.
We help the CCO and management team think through administration, testing, certifications, compliance calendars, and recordkeeping so the program is workable after the documents are finalized.
Off-the-shelf manuals often create problems when they describe controls the firm does not actually follow or ignore risks the firm really has. We focus on drafting a program that fits the adviser in front of us.
A compliance program works better when the documents are clear, the workflow is manageable, and the expectations are realistic. We structure the program so the Chief Compliance Officer has a framework that can actually be administered.
We follow current SEC guidance, risk alerts, and examination observations closely. That helps us draft policies and procedures with an eye toward the areas regulators often review, while keeping the language tailored to the firm’s actual operations.
A compliance program should work with the firm’s real structure, including custodians, administrators, portfolio systems, and internal approval processes. We focus on building something the adviser can actually use on an ongoing basis.
Rule 206(4)-7 under the Advisers Act requires each SEC-registered investment adviser to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act, review those policies and procedures at least annually, and designate a Chief Compliance Officer to administer the program.
Software can be helpful for workflow and task management, but standard templates still need to be tailored carefully. The main issue is not whether a manual looks complete; it is whether the policies actually fit the firm’s business and are followed in practice.
Yes. Under SEC Rule 204A-1, registered investment advisers must adopt, maintain, and enforce a written Code of Ethics. Among other things, it must set standards of conduct, require compliance with the federal securities laws, and address personal securities holdings and transaction reporting for access persons.
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