This review is a targeted version of examinations conducted by securities regulators. For new clients, this provides Tirador a way to learn your business while screening for the most common deficiencies cited in examinations. Ongoing clients may elect this review on a periodic basis to confirm that key compliance elements remain in place. This review includes an examination-style interview to help you prepare for your next regulatory examination.
Annual Reviews and Updates
There are four major recurring requirements for every RIA*. Tirador works with each client personally on these reviews, and recommends the following schedule:
- Annual ADV Amendment – Q1: All RIAs are required to file an annual amendment by 90 days after the end of the firm’s fiscal year, which is March 31 for firms whose fiscal year ends December 31. Tirador helps you to ensure that the updates are accurate and timely, while minimizing the time taken away from running your firm.
- Policies & Procedures/Books & Records Review – Q2: All advisory firms are required to have written supervisory procedures and to maintain specific books and records. Your supervisory procedures should reflect your firm’s business and scale and should correspond to the regulations under which your firm operates (i.e. state or SEC). Your books and records then document that you follow your own policies.
- Cybersecurity Review – Q3: This review begins with a screen sharing session to inventory your IT systems and document your cybersecurity measures. On completion, you will have an inventory of your IT hardware, security software, and systems to address the annual cybersecurity requirement. You will receive a short cybersecurity policy document, an incident response plan, and reference materials on cybersecurity for small business from the Federal Trade Commission.
- Business Continuity Planning – Q4: Regulators require every advisory firm to have a written Business Continuity Plan (BCP), and to review it at least annually. It doesn't have to be elaborate, but it must address essential elements. Business continuity for a small firm needs to address key person risk – what will happen if a key person is incapacitated, unavailable, or dies? Most BCP templates don’t address this, and it is akin to your RIA having an estate plan.
*Some states have not yet implemented the NASAA Model Rules for Cybersecurity and Business Continuity Planning, but these items remain key to running a good practice and fulfilling your fiduciary duty.
New RIA Registration
Launching your firm is a busy time for you. We don't send you questionnaires to fill out (effectively making you write your own documents). We will learn your business through one-on-one conversations, then we build your registration and compliance documents.
State-Registered RIA Compliance Manual
Tirador’s exclusive manual, customized to your firm and processes, is built directly on the RIA regulations that apply to your firm. Off-the-shelf manuals purchased by state-regulated firms often contain inapplicable SEC regulations and extensive procedures that just don't fit small RIA shops.
We love it when our clients succeed! We can facilitate the regulatory filings, help prepare your firm for the differences between state and SEC regulation, and continue to support your compliance program once SEC registration kicks in!
- Firm Registration - Your ADV describes your business to the regulators.
- Annual Updates - Due within 90 days of year end, these review and update your firm's registration information.
- Amendments - Your registration information must be updated timely whenever there is a change in your business.
- ADV Part 2A (Brochure) - Just like ADV Part 1, this plain-English document describes your firm's business to clients and prospects.
- ADV Part 2B - All IA firms must have Part 2B, and state-registered firms must include the 2B in registrations and updates.
- U4/U5 Maintenance - Each representative's information needs to be accurate and up-to-date.
*Tirador Compliance LLC does not provide legal, tax, or financial advice.