• 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.

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