RIA SERVICES

Registering a new firm with the SEC can be complex and time-consuming. 

To register with the SEC as an investment adviser, you must file Form ADV Part 1 and comply with the "brochure rule," Parts 2A & 2B, and Form CRS, which requires advisers to provide clients and prospective clients with information about the adviser's business practices and educational and business background.

The rule also states that advisers must maintain current and accurate books and records, as specified by SEC rules, and be subject to inspection and examination by the SEC. 

ICA can help guide you as you navigate your new registration and compliance platform so you can focus on your firm and clients.

ICA will comprehensively review your current SEC or State registration filing, existing disclosure brochures, and your current IA agreements.

We will highlight any necessary recommendations, revise the language, and address regulatory concerns.

Creating a culture of compliance begins with ICA and the firm’s CCO, senior management, and operations team. The firm’s compliance department, senior management, and key operational management are responsible for creating effective internal controls for complete books and records.

To satisfy the regulator's expectations, firms must demonstrate informed oversight and a detailed risk analysis documenting comprehensive controls to address legal and regulatory requirements.

Essential Services provide firms with the policies and procedures, forms, agreements, and testing checklists to comply with all regulatory compliance expectations. ICA will assist CCOs and provide guidance with tailoring and implementing firm policies and procedures, task calendars, checklists, and extensive testing tools.

The Fundamental Service level is built for firms with a seasoned in-house CCO requesting support and guidance in developing and integrating compliance, policies and procedures, processes, and reviewing the firm's risk level.

SEC examiners will request the firm's risk analysis to review the level of inherent risk and risk controls. A sound and well-constructed risk assessment is the foundation of a methodical, measured, and proactive approach to a firm's compliance challenges in this ever-changing regulatory environment. The absence of risk assessment, adequately tailored processes and policies, and management oversight may indicate a weakness in the culture of compliance and compliance management functions.

CCOs and senior management are responsible for ensuring regulatory compliance; therefore, C-level executives should actively implement, analyze, review, and approve the compliance program and conduct a complete risk analysis.

The Integrated Service level is developed and customized for firms with an in-house CCO looking to expand their purview of all aspects of the compliance department. ICA will work closely with the firm's CCO and management and integrate best practices with weekly calls to mentor and coach CCOs.

With a personalized, tailored approach, we will implement all services from the Essential and Fundamental levels, conduct a complete risk assessment, explore several types of mock exams, properly document processes and policies, and demonstrate a culture of compliance. Internal testing with ICA will provide additional advice, recommendations, and remediation for gaps in existing policies, controls, and processes consistent with regulatory exams and expectations.

The ICA Integrated Services difference is the high-level education we provide to CCOs to give them organizational independence and objectivity, evidenced by the firm’s culture of compliance.

ICA offers additional services for firms looking to conduct a risk analysis, SEC mock exams, or needing assistance with developing their compliance program. Please contact our office for more information.

ICA offers hourly consulting engagements to firms who need assistance with exams or one-off projects. Please get in touch with our office to learn more.