SEC Services for Registered Investment Advisors

Our compliance support services include:

Forms ADV I & ADV II

• The Investment Advisers Act and relevant state registration laws require advisers to file accurate and truthful forms. Our professionals will perform a full review of your firm, its organizational structure, potential conflicts of interest, supervisory oversight, investment advisory activities, activities of related persons, regulatory history and compliance practices. With this information, we can revise and update the Forms ADV I & ADV II to be accurate in all material respects.

Compliance Program Design

• Our investment adviser clients range from small to large – from separate account clients to multi-billion AUM advisers with both separate account and private fund clients, and everything in between. We work to ensure that your compliance program is tailored to fit your business.

Risk Assessment

• Risk assessments and internal control reports capture the full inventory of compliance risks and assign a risk rating for each compliance risk. The drafting of written policies and procedures flows from this.

Form CRS

• We work with advisors to help draft true and accurate relationship summary forms to comply with the new CRS form rule.

Compliance Policies & Procedures

• Multiple laws may apply to your advisory business, e.g. the Advisers Act, Regulation S-P, state securities laws, 1933 Act, 1934 Act, and rules and regulations as promulgated. Our staff can draft and/or amend compliance policies and procedures to maintain your compliance with such laws.

Compliance Testing

• Aviolo can perform compliance monitoring and forensic testing required by your compliance policies and procedures, or otherwise test certain aspects of your compliance program.

Annual Compliance Review

• Aviolo can perform the annual compliance review required by Rule 206(4)-7 of the Advisers Act and prepare the associated report regarding the adequacy of your compliance policies and procedures, and the effectiveness of their implementation. Our reviews conform to guidance published by the SEC for the conduct of 206(4)-7 reviews.

Marketing & Advertisement Reviews

• Aviolo can analyse all your advertising materials (including websites, blogs and social media) to ensure compliance with the advertising rule (as modified by SEC guidance) and state laws. As part of this, we can draft the necessary disclosures to advertising materials to assist in complying with your obligation to provide disclosure of all material facts.

Regulatory Examinations

• In the event of an SEC examination, either a correspondence exam or on-site, Aviolo can provide on-site assistance, serving as contact point for the regulators, participating in calls and meetings, assisting with document requests as well as drafting responses to deficiency letters and regulatory inquiries.

Mock Exams

• Because our people are seasoned professionals with in-depth SEC knowledge and experience, we can conduct a mock examination of your advisory business, including interviews with key personnel, reviews of relevant documents and testing, and prepare a written report of our findings. We will gather the requested documents, review them for completeness, and organize these documents in SEC examination formats.

Deficiency Letters

• Because we have already assisted with SEC exams, we are well versed in preparing responses to SEC deficiency letters.

Compliance Training

• Aviolo can conduct compliance trainings for the entire organisation or for key members, e.g., chief compliance officers and staff. These can be done in-person, remotely via Skype/webinars or by us preparing material for internal presentations.

Cyber Security

• Aviolo can help develop policies and procedures for investment advisers to maintain compliance with current regulatory requirements for protecting personally identifiable information for advisory clients – particularly important as this tends to change quite rapidly. Aviolo also conducts staff training and compliance testing with respect to cyber security.

Business Continuity/Disaster Recovery Plan.

• Aviolo can develop plans to maintain effective business operations in the event of a significant business disruption, as well as periodic or annual testing.

Code of Ethics

• Aviolo can help ensure your code of ethics complies with Rule 204A-1, and is appropriate for your business. The code should cover more than simply personal trading, it should provide a standard of conduct and require oversight of potential conflicts, e.g., outside business activities, gifts and entertainment.

Compliance Calendars and Regulatory Reminders

• Aviolo develops customized compliance calendars to help keep advisers on track with legal requirements (deadlines for Forms ADV I & II, Form PF, Form CRS, Section 13 reporting), personnel reporting obligations (deadlines for personal securities reporting, periodic attestations) and compliance testing.

Best Execution

• Aviolo can ensure that your best execution policies and procedures are appropriate for your business, in addition, we can hold or participate in best execution review meetings to guide the process. We can conduct periodic qualitative analyses to determine whether your clients are receiving best execution in accordance with SEC requirements and prepare written best execution reports.

Trade Surveillance

• Aviolo can perform reviews of trades regularly to identify issues that could cause concern to regulators such as front-running, window dressing, cherry picking, cross trade issues and other areas.

IARD Administration

• Aviolo can support all regulatory filings, including state notice filings, and perform annual investment adviser registration renewals.

Form PF

• Aviolo can create a timeline and key milestones with your service providers (external auditor, fund accountant, administrator, outside counsel, etc.) and obtain all required information and data in order to properly draft and file Form PF.

Email/Instant Messaging Surveillance

• Aviolo can help find solutions regarding Emails and instant messages to identify non-compliant activities and produce a comprehensive memo highlighting issues found.

Watch/Restricted List

• Aviolo can create, maintain, and distribute securities watch and restricted lists.

Employee Trading Reviews

• Aviolo can review personal securities transaction statements each quarter to help advisers comply with Code of Ethics requirements.

Due Diligence Questionnaires/RFPs

• Aviolo can conduct a compliance review of due diligence questionnaires and requests for proposals completed by your investment adviser for any potential inaccuracies or misrepresentations prior to dissemination.

Suitability Reviews

• Aviolo can perform reviews of client portfolios to ensure compatibility with each client’s investment objectives and risk tolerance.

Undisclosed Disciplinary Action Reviews

Aviolo can help research and confirm whether any supervised persons have not disclosed full disciplinary histories.

Outside Business Activity Oversight

• Aviolo conducts research and reviews of outside business activities of supervised persons to identify any conflicts of interest.

Books & Records

• Aviolo can create and maintain books and records required by the Advisers Act and state laws.

Agreements & Contracts

• Aviolo can review and update your advisory agreements and other agreements to ensure they comply with the requirements of the Advisers Act and other SEC positions, e.g., hedge clauses.

Additional Services

• Additional testing, reviews and consulting can be completed by our team on an as needed, as requested basis, and rolled into whichever service may best fit your needs, or we can perform one-time engagements.