As part of the Investment Advisers Act of 1940 Rule 206 (4) – 7 (17 CFR 275.206(4)-7), investment advisers and dually registered firms are required to conduct annual reviews of their policies and procedures to assess their adequacy and effectiveness. In a 2017 Risk Alert, SEC staff noted that failure to conduct annual reviews, as required, or to address the adequacy of policies and procedures as a part of such reviews, were among the most frequently cited compliance issues cited in examinations. Non-compliance can result in firms incurring fines and penalties.
NRS consultant compliance professionals can help firms meet this annual requirement. NRS expert compliance professionals work with you, facilitating on-site reviews of applicable rules and regulations to assess compliance, allowing you to meet the annual review requirement and to determine the effectiveness of your firm’s compliance program.