What Compliance Services Can You Outsource?

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Ways An Outsourced Compliance Consulting Firm Can Be Utilized

There are many ways an independent compliance perspective, through an outsourced consultant, can bring value to your firm. Coast to Coast Compliance can help give your firm and staff the credit it deserves for an effective compliance program and a strong culture of compliance. By leveraging our outsourced compliance offerings (including, but not limited to the following services), investment advisers can manage their compliance requirements more efficiently, while primarily focusing on their core business activities.

Third-Party Compliance Officer

Outsourcing to an independent compliance consultant can be particularly helpful to establish a compliance framework and develop a compliance program for a newly launching investment adviser or other financial services firm. For an already established adviser Coast to Coast Compliance understands that urgent situations may arise which result in an immediate need to fill a vacancy. Our goal is to be a flexible option to help bridge a gap or provide additional resources, temporary, interim, fractional, or otherwise, dependent on the specific needs of the firm.

Compliance Policies and Procedures

SEC and state-registered investment advisers are required to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and other laws. Exempt reporting advisers must also implement written policies and procedures reasonably designed to prevent the misuse of material non-public information (under Section 204 of the Advisers Act). Through the course of due diligence on behalf of prospective investors and/or third-party service providers, many other types of investment advisers, alternative asset managers, and other financial services firms find themselves needing to develop customized policies and procedures.

Whether regulator-driven, investor-driven, or otherwise, Coast to Coast Compliance can provide your firm with a customized and comprehensive Compliance Manual (as required by Rule 206(4)-7 of the Advisers Act), Code of Ethics (as required by Rule 204A-1 of the Advisers Act), or any other relevant policies and procedures. For established firms, we can review and revise existing compliance policies and procedures, to provide relevant recommendations from an independent perspective.

Compliance Training for Employees

In a constantly evolving regulatory environment, properly trained and empowered compliance professionals are essential to the success of a compliance program and help reduce regulatory, financial, and other risks. Whether you are a newly formed investment adviser seeking to conduct an initial firm-wide compliance training or an established firm seeking to conduct a firm-wide annual compliance training refresher, Coast to Coast Compliance can build customized compliance training specific to the needs of your firm and its personnel. Coast to Coast Compliance can also remain an as-needed resource for your firm and develop new-hire employee compliance training, or customized compliance training to keep your CCO and/or compliance personnel current on the latest regulatory requirements and best practices.

Mock SEC Examinations

SEC and state-registered investment advisers are generally interested in conducting a mock examination within the first few years of becoming registered (as they can be examined at any time once registered), as well as every few years thereafter. Coast to Coast Compliance can conduct a mock SEC examination which includes the requesting and reviewing of key compliance and business documents, as well as the interviewing of various firm personnel. By identifying any compliance gaps and areas for improvement, while guiding investment advisers through the process of an SEC exam, Coast to Coast Compliance can help give your firm and staff the confidence and preparedness to succeed in an SEC examination.

Annual Compliance Program Reviews

Failing to conduct an annual review has been a consistently cited compliance issue in SEC examinations and can result in fines and penalties. Rule 206(4)-7 under the Advisers Act requires SEC-registered investment advisers to annually review their written policies and procedures to determine their adequacy and the effectiveness of their implementation. Coast to Coast Compliance can conduct a comprehensive review of your firm’s policies and procedures, as well as the completeness and effectiveness of its overall compliance program. We can provide a written annual review report documenting the scope of our review, relevant findings, and any resulting recommendations.

Regulatory Exam Assistance

Whether you’ve never been examined by the SEC, or several years have passed since a previous examination, even the most prepared investment advisers and other financial services firms, can benefit from guidance during an examination and assistance responding to a deficiency letter. Coast to Coast Compliance will guide you through the regulatory examination process, will assist you drafting a response to any deficiency letter, and will provide and help implement relevant compliance solutions required as a result of the examination.