Best Practices for
Investment Advisers
- Prepare and maintain all required records, including financial records. Back-up electronic data and protect records. Document checks forwarded.
- Review and revise Form ADV and disclosure brochure annually to reflect current and accurate information.
- Review and update all contracts.
- Prepare and distribute a privacy policy initially and annually.
- Deliver disclosure brochure initially and annually as required.
- Review all advertisements, including website and performance advertising, for accuracy.
- Calculate and document fees correctly in accordance with contracts and ADV.
- Prepare and maintain written compliance and supervisory procedures relevant to the type of business to include business continuity plan. Assess and update periodically.
- Implement appropriate custody safeguards, as applicable. Pay close attention to direct fee deduction invoices.
- Keep accurate financials. File timely with the jurisdiction. Maintain surety bond if required.
- Make sure client’s investment policy and suitability information are current.
- Disclose soft dollars or benefits received.
- Prepare and maintain current client profiles.
- Review solicitor agreements, disclosure, and delivery procedures.
North American Securities Administrators Association | www.nasaa.org
