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Compliance Considerations at Quarter End

The end of a quarter often nudges one to stop and think about those aspects of the business that are easy to forget or ignore during the usual day to day operations of the RIA. Addressing compliance concerns, every adviser’s favorite side task, is potentially a good thing to get onto your calendar and front of mind at this time of year.
What has changed at the firm and with its policies and procedures? Should the firm’s ADV Part 2 be updated? Good indicators of a need to do an update include new advisory personnel, new products or services offered, or the addition or replacement of an outside broker-dealer or custodian used by the firm.
How about the status of ongoing internal operations? Is it time to perform a review of trade errors, test best execution, check the review and approval status of advertising disseminated over the past few months? Are there any adverse actions or reports involving the firm or its personnel? Review the client complaint file, too.
Looking at the outward facing aspects of the firm, have there been (or do there need to be) updates to the firm website? Is it time for sending clients their annual copy of your privacy policy or an offer to provide the latest form ADV Part 2? And with end of quarter reporting, performance claims and advertising materials should be reviewed and approved before sending.
Compliance requirements and the attention of the regulators is always with us so it is nice to take a few moments and ensure that we are up to speed and won’t have to worry about falling behind. 

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