Serving Investment Advisers both Nationally and Internationally
Gery Sadzewicz Consulting LLC can either function as your firm’s Chief Compliance Officer (CCO) or provide a complete suite of services to support your firm’s named CCO. We will help you identify regulatory and risk management challenges, and then build and implement a practical solution that satisfies all of your compliance obligations. Our complete CCO outsourcing services include the following:
- Annual compliance testing, which includes annual audit and report to management as well as a review of the firm’s current businesses to ensure adequacy of compliance policies and procedures
- ADV maintenance and updating via IARD
- Preparation and maintenance of disclosure language
- Ongoing maintenance of compliance manual and written supervisory procedures (includes development of compliance manual and written supervisory procedures as needed)
- Best execution, order aggregation, security, and trade allocation reviews
- Quarterly personal trading account reviews
- Email reviews
- Maintenance of restricted and watch lists as applicable
- Annual compliance meetings
- Continuing education as applicable
- Annual certifications (distribution, completion, collection, and record maintenance)
- Client suitability reviews
- Annual due diligence review to ensure adequacy of current due diligence procedures
- Reviews to ensure timely and accurate annual compliance notification
- U-4 /U-5 preparation and review
- All other work necessary to ensure compliance with applicable rules given the firm’s business model
- Registration with SEC and state regulatory authorities:
- Registration as an investment adviser with either the SEC or applicable state regulatory authorities:
- Preparation of all registration documents (Form ADV Parts 1 and 2, Form CRS, Schedule F)
- Monitoring of progress from start to finish
- Development of compliance and operating procedures manuals, code of ethics, privacy notice, engagement letter templates (must be reviewed with outside legal counsel), and all other applicable documents required to register, operate, and supervise the advisory firm