Annual Reviews

All SEC-registered advisers, as well as those engaging in established best practices, are required to perform an annual review of the firm’s Compliance Program under Rule 206(4)-7. This is a review and testing of the firm’s Policies and Procedures and Compliance controls, culminating in a summary letter of the findings and remedial recommendations. Bates Compliance’s consultants have performed Annual Reviews for a wide range of clients, from small, one-member firms to some of the largest in the industry. Bates Compliance has extensive testing methodologies it uses to effectively “Pressure Test” a firm’s policies, determining if and where weaknesses exists and suggesting corrective measures the firm should implement. As supervision continues to top the SEC’s exam priority list, having a sound compliance program begins with having a sound compliance manual.