The manual, the code and the acknowledgments, on record by version.

For chief compliance officers at registered investment advisers, and the outsourced CCOs who work with them. The compliance manual and the code of ethics approved, sent to every supervised person and kept by version.

30-day trialUnlimited free viewersNo credit card required

Four colleagues around a conference table with laptops, one speaking and the others listening.

What the examiner asks for

The first-day request names the manual in force during the exam period, the code of ethics and its acknowledgments, and what the last annual review left behind.

SEC Rule 206(4)-7(a)

Compliance policies and procedures

Written policies and procedures, adopted and implemented, reasonably designed to prevent violations of the Advisers Act.

  • Every version in effect during the exam period
  • Who approved each version, and when
  • Proof the people it covers received it

SEC Rules 206(4)-7(b) and 204-2(a)(17)(ii)

The annual review

A review at least once a year of whether the policies are adequate and carried out effectively, with any records that document it.

  • A review date on the manual that brings the review around each year
  • A re-approval or a revised version on record
  • The comparison showing what the review changed

SEC Rule 204A-1

Code of ethics and acknowledgments

A written code of ethics, and from every supervised person a written acknowledgment that they received it and each amendment to it.

  • Each person’s acknowledgment of the code
  • An acknowledgment for every amendment
  • Name, date, time and version on each record

SEC Rule 204-2

Books and records

The records the rules require, kept for the periods they set, including the policies in effect over the past five years.

  • Policy versions kept and retrievable
  • The acknowledgments behind each code version
  • Records documenting each review

How it helps a firm

Built for chief compliance officers who show examiners the manual, the code and the record.

The right policy to each person

Advisers, access persons and operations each get the procedures that cover them.

New hires covered from day one

Invite a new adviser with their tags and the code and manual are waiting.

No seat cost for staff

Supervised persons and other viewers are unlimited. You pay for the people who write.

Every amendment sent again

A revised code or manual is approved, then its Editor sends it out and everyone it covers is asked again.

Annual reviews on schedule

A review date puts an alert on the manual and reminds its Editor.

Proof on request

Filter the audit log by date or person and export a PDF or CSV.

Each team gets its own policies

Tag people by office, team and role. Each policy reaches only the people it covers, and new hires get theirs on day one.

A record for every supervised person

Show the examiner each person’s acknowledgment of the code and every amendment, with the time and the version.

The rest of the manual

The rules set the frame, and the adopting release expects the manual to fit the firm. Each area your firm covers is a policy that needs the same control.

Personal and proprietary trading

The procedure current, with each access person’s acknowledgment of it by version.

Marketing and advertising

Review procedures versioned, so every adviser works from the same rules.

Safeguarding client assets

The procedure approved and current for everyone who handles client assets.

Privacy and information security

One current version of each policy, with its history kept and its readers on record.

Business continuity

The plan current and in the hands of everyone who has a role in it.

Handbook and acceptable use

One current version for every employee, confirmed when it changes.

Ready for whoever asks.

The first-day request names the manual as it stood, the code of ethics, its acknowledgments and the annual review. Each is an approved document with its own record.

Filter the audit log by date or person and export it as a PDF or CSV.

  • The manualThe version in effect on any date, and who approved it
  • The code of ethicsEach supervised person’s acknowledgment, by version
  • The annual reviewA review date, and the re-approval or revised version it produced
  • Outside counselInvite your lawyer to approve policies before they go out

Built around your firm

Offices and teamsTags such as Advisers, Trading or Operations send each policy only to the people it covers.
Outside counselInvite your lawyer to approve policies before they go out.
Your outsourced CCOInvite them as an Editor when they write or maintain your policies.
ExaminersGive an examiner Viewer access to the documents their tags allow.

Need help writing the policies? Find a consultant for your standard.

Questions

Do supervised persons need a paid seat?

No. They read and acknowledge as viewers, free of charge.

Acknowledgment or signature?

Both are available. Choose for each policy when you send it. E-sign is an optional add-on.

What happens when the code of ethics changes?

The revised code is approved as a new version, its Editor sends it out again, and everyone it covers is asked to acknowledge it. Earlier acknowledgments stay on record.

Does the setup differ for a state-registered adviser?

The mechanics are the same: write your policies, approve them, send them to the people they cover and keep the record. Bring the rules you answer to.

Can our outsourced CCO run this for us?

Yes. Invite them as an Editor if they write or maintain the policies.

What do we hand the examiner?

Export the document’s log, or the workspace audit log if you are an Admin, as a PDF or CSV, filtered by date or person.

What happens to someone’s record when they leave?

Their completed acknowledgments stay on record.

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