neaThe following list is the North American Securities Administrators Association's (NASAA) recommendations for the best practices that investment advisers should consider to minimize regulatory violations.

 

  • Review and revise Form ADV and disclosure brochure annually to reflect current and accurate information.
  • Review and update all contracts.
  • Prepare and maintain all required records, including financial records.
  • Back-up electronic data and protect records.
  • Document all forwarded checks.
  • Prepare and maintain client profiles.
  • Prepare a written compliance and supervisory procedures manual relevant to the type of business, including a business continuity plan.
  • Prepare and distribute a privacy policy initially and annually.
  • Keep accurate financials. File on time with the jurisdiction.
  • Maintain surety bond if required.
  • Calculate and document fees correctly in accordance with contracts and ADV.
  • Review all advertisements, including website and performance advertising, for accuracy.
  • Implement appropriate custody safeguards, if applicable.
  • Review solicitor agreements, disclosure and delivery procedures.
Source: National Ethics Association and the North American Securities Administrators Association (NASAA).
 
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