Investment Advisor Regulation and Compliance Matters

• Registration issues
• Form ADV, schedules and disclosures
• Day-to-day compliance issues and guidance
• Risk management reviews and assessments
• Compliance system reviews and drafting of procedures and manuals
• Advertising, sales material, and brochure reviews
• Portfolio and performance disclosure issues; GIPS Standards
• Code of Ethics issues and reporting
• Compliance annual reviews under Investment Advisers Act
• Rule 206(4)-7 and Investment Company Act Rule 38a-1
• Anti-money laundering requirements and related programs
• Review and analysis of financial planning activities and disclosures

Broker-Dealer Regulation and Compliance Matters

• FINRA membership process and SEC registration
• Broker-dealer registration issues
• Form BD, schedules and disclosures
• Form U-4 and Form U-5 disclosures and filings
• Registered representative registration and qualification issues with SROs and states
• Day-to-day compliance and operational issues and guidance
• Risk management reviews and assessments
• Compliance system reviews and drafting of procedures and manuals
• Firm supervisory structure and branch office issues
• Advertising, sales material, and brochure reviews
• Code of Ethics issues and reporting
• Compliance annual certification under FINRA Rules
• Anti-money laundering requirements and related programs
• Continuing education requirements and annual compliance meeting content

Regulatory Inquiries, Examinations and Enforcement Actions

• Counsel and represent Clients in examinations and regulatory and enforcement actions by SEC, FINRA, exchanges, and states
• Assist Clients with examination and deficiency letter responses
• Counsel on examination preparation, design and conduct mock examinations
• On the record interviews (OTRs), preparation and subpoena responses
• Advise on books and records issues; design and conduct reviews

Provide Legal and Regulatory Counsel on New Business Initiatives

• Design and conduct gap analysis for compliance and supervisory procedures and other control systems and procedures
• Draft new procedures, agreements, and required disclosures

Legal Agreement Review and drafting:

• Client Investment management and referral agreements
• Separate account agreements
• Wrap-fee program agreements
• Unified managed account agreements
• Client agreements and related disclosures
• Vendor and technology agreements
• Employment agreements
• Confidentiality agreements
• Non-disclosure agreements
• Agreements limiting competition