Ongoing compliance support and annual review assistance designed to help RIAs test their programs, update their policies, and respond to issues before they become larger problems.
Having a compliance manual in place is only one part of the job. Under Rule 206(4)-7, SEC-registered advisers must review their policies and procedures at least annually for adequacy and the effectiveness of implementation. The annual review is most useful when it looks at how the firm is actually operating, what changed during the year, and where the program may need to be updated.
At Ishimbayev Law Firm, we help advisers approach the annual review and ongoing compliance process in a practical way. We support Chief Compliance Officers and management teams with targeted testing, issue-spotting, policy updates, and day-to-day legal guidance so the program stays aligned with the business as it evolves.
Assisting with annual compliance reviews, including scoped testing, issue identification, and documentation designed to reflect the firm’s business, risks, and current operating practices.
Conducting mock examinations and readiness reviews based on current SEC examination focus areas to help advisers identify gaps and improve responses before an actual exam.
Serving as outside counsel on day-to-day compliance questions, marketing reviews, policy interpretation, and other issues that arise between annual review cycles.
Reviewing developments in SEC and state regulatory guidance and helping update compliance manuals, codes, and related disclosures where changes in the business or legal landscape call for revisions.
We focus first on the areas that matter most for the firm, which may include trading, fees and expenses, marketing, books and records, personal trading, valuation, custody, or vendor oversight, depending on the adviser’s model.
When issues surface, we help clients think through realistic next steps—whether that means revising a policy, tightening a workflow, improving documentation, or addressing a disclosure mismatch.
We help structure the annual review documentation and related follow-up materials in a way that is useful for the firm internally and more defensible if reviewed later by regulators or investors.
We follow SEC examination observations, risk alerts, and enforcement themes closely. That helps us focus the review on areas that regulators often examine without turning the process into something more burdensome than it needs to be.
Many advisers already have an internal CCO or compliance lead. Our role is often to support that person with outside legal judgment, extra bandwidth, and a fresh review of areas that deserve closer attention.
Good compliance work is easier to defend when the program, the testing, and the resulting updates are documented clearly. We help clients organize that process in a way that is more coherent and easier to maintain over time.
The annual review is easier when it is approached as an ongoing process rather than a year-end scramble. We help clients build a cadence for testing, updates, and follow-up so the work is more orderly across the year.
Yes. For SEC-registered investment advisers, Rule 206(4)-7 requires an annual review of the adviser’s policies and procedures to assess their adequacy and the effectiveness of implementation.
At a minimum, advisers should maintain records documenting the annual review required by Rule 206(4)-7. Weak or missing documentation can create unnecessary recordkeeping and examination issues and may make it harder to show how the firm identified, assessed, and addressed compliance matters over time.
The annual review is part of the adviser’s compliance obligations under Rule 206(4)-7. A mock SEC exam is a separate readiness exercise that simulates regulatory requests and testing so the firm can see how its documents, personnel, and processes hold up under examination conditions.
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