Best Practices for
Investment Advisers
- Prepare and maintain all required records, including financial records. Back-up electronic data and protect records. Document checks and securities forwarded.
- Review and revise Form ADV and disclosure brochure annually to reflect current and accurate information.
- Formulate and document cybersecurity policies, procedures, and measures.
- Review and update all contracts. Contracts should be reviewed by the Commission staff prior to use. Keep records of how this was disseminated.
- Prepare and distribute a privacy policy initially and annually. Keep records of how this was disseminated. Be aware of confidential information transmitted via unsecure means.
- Deliver disclosure brochure initially and annually as required. Keep records of how this was disseminated.
- Review for accuracy and maintain all advertisements, including but not limited to website, all social media and performance advertising.
- Calculate and document fees correctly in accordance with contracts and ADV.
- Prepare and maintain written compliance and supervisory procedures manual that is relevant to the type of business to include business continuity plan and information security policies/procedures. 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.
- Maintain current client profiles or other client suitability information. Maintain a due diligence file for recommended products or strategy.
- Disclose soft dollars or benefits received.
- Add policies/procedures for seniors/vulnerable persons to include training of personnel.
- Review solicitor agreements, disclosure, and delivery procedures.
North American Securities Administrators Association | www.nasaa.org
