A Checklist to Improve Your Annual Review Process

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Does conducting your firm’s internal annual review have to cause annual stress, work overload, and a headache?

No.

The annual review burden that investment advisors feel is the result of cramming the process into a few days’ work. Your annual review isn’t something that should be conducted over the course of a couple days. To thoroughly conduct your review, your compliance team must integrate aspects of the review process into their day-to-day activities.

Under Rule 206(4)-7, firms must:

  1. Adopt and implement written customized policies and procedures;
  2. Designate a chief compliance officer;
  3. Conduct annual review of policies and procedures; and
  4. Maintain records of policies and procedures and annual reviews.