Dear RIA CCO: Are you ready for 2020? Let’s prepare and collaborate.
It’s almost Halloween, where did 2019 go? I’m still behind and have no costumes for my three boys, but I get things done by my deadline… always!
Let’s talk Compliance for the new year of 2020! There is the usual calendar (which I will post), however, I have a quick read prep list for those interested. 🙂
RIA Annual Filing: Start getting your stuff (or sh*t) together early! If you have a December fiscal year-end, create a detailed plan with your team to have your items in order. If you are a larger firm, it takes time to gather the ADV data (ya, I was the underling gatherer, it takes time). Make sure you have a plan so you aren’t pressed or stressed for time when submitting your annual ADV filing.
Policies and Procedures Review: Regulatory bodies draw a hardline on Written Supervisory Procedures (WSPs). If your firm is audited by state or federal authorties, they want to see that your firm has followed your WSPs, document everything! Thoroughly read and evaluate all compliance documents for accuracy, effectiveness and regulatory compliance; also possible changes of regulatory laws. Make sure your Business Continuity Plan is up-to-date. Physically TEST and DOCUMENT the results and possible revisions to your BCP.
Wrap up 2019 ASAP: Ensure your compliance requirements are compete for Q4. Keep in mind it’s sometimes difficult to get ahold of advisers during the holidays, or maybe they just ignore your compliance requests in general, lol. Make sure you have all attestations and items you need early in Q4, so you can get ready for Q1 2020!
Evaluate Firm Budget: Take a look at what worked for your firm, what did not. Where your firm can save money while still having the upmost in compliance quality. Did your firm outsource tasks or were you able to automate any requirements to save your firm time and money? Evaluate the option of outsourcing vs. in-house compliance professionals.
Mutual Fund Share Class Initiative: Ensure your firm is compliant in this area to avoid fines, it’s a heavily enforced initiative right now. Click here for the full detailed seven page SEC document about mutual fund share class violations and conflicts of interest that can affect your firm.
I’m out on a Wednesday, glad we are close to Fri-yay! Have a great rest of your week!
Cheers from Sonja Rae @ RIA-CCO
