Annual Reviews – More Complicated in The Age of COVID
In these unprecedented times the preparation of the Annual review may be even more daunting, taking considerably more time and other resources to complete.
The Investment Advisers Act of 1940 requires each Registered Investment Adviser to review its compliance policies and procedures annually to determine the adequacy and effectiveness of their implementation, and consider new regulations and changes to the business that may impact the policies and procedures. Similarly, the Investment Company Act of 1940 requires institutions and funds to review their policies and procedures, as well as those of their service providers, at least annually.
Regulators also expect registered firms to document the results of these reviews, but while they provide broad guidance, they do not stipulate how the annual review should be conducted or evidenced. Approaches to the annual review may vary depending on a firm’s size and resources.
During the height of the pandemic, the SEC increased their focus and examination scrutiny in several areas including improper trading on material nonpublic information; disclosure and investor communications; valuations; and business continuity plans (“BCPs”), CCOs would be advised to address these areas during their annual review.1
Through our participation in more than 100 regulatory examinations as Chief Compliance Officers, the Alaric team is in the unique position of understanding current regulatory trends and having the hands-on experience to help clients identify issues before they become violations.
We offer cost-effective solutions that are flexible and tailored to meet our clients’ specific needs.
To learn more about how Alaric can help you in the preparation of your annual review please visit www.alariccompliance.com. We can be reached at 1-888-243-2448, or email firstname.lastname@example.org.
1 Alaric Compliance Alert, April 20, 2020, Do Not Neglect Your Compliance Health During the COVID-19 Pandemic, https://www.alariccompliance.com/do-not-neglect-your-compliance-health-during-the-covid-19-pandemic