Compliance Solutions for Investment Advisers

SEC Audits – 6 Items

According to Junxure’s Greg Friedman a SEC audit is all about the data and how to get to it fast, specifically these six:

1. Client lists — current clients, ex-clients, wrap-fee clients, related persons, etc.

2. Contact lists — vendors, advisors to firm, etc.

3. Important dates — account inception date, termination date, contract date, etc.

4. Important account data — discretionary?  Managed?  Type of Account?

5. Client communication — email, correspondence

6. Demonstrating a “culture of compliance” — recurring actions, action sequences, action templates

Not saying he is wrong, but he is trying to sell CRM software . . .

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