Our Services

Our Services

What We Offer

ASG's compliance services are designed to educate you on the regulations that affect your business, help you create and maintain an effective compliance program, and to prepare you for a visit from a regulator. Our objective is to make the burden of complying with Federal and State regulations as non-invasive and as cost-effective as possible, leaving you free to focus your resources on managing money. We begin each new client relationship with a detailed process to get to know you and your business.

After a complimentary telephone or in-person meeting, ASG will provide you with a custom quote for comprehensive compliance services based on your firm’s size, affiliations, and services offered.

Registration Assistance

  • Full Service Registration, whether SEC or state

    • Prepare IARD entitlement forms
    • Prepare & submit Form ADV Part 1 on the IARD system
    • Prepare & submit Form ADV Part 2A and Appendix 1
    • Prepare & submit Form ADV Part 2B Supplements
    • Prepare & submit Form U-4 for investment adviser representatives on the CRD system
    • Submit all required documentation with the SEC or State(s)
    • Provide a sample investment advisory agreement
    • Create a customized Privacy Notice (as required by the Graham-Leach-Bliley Act)
    • Respond to regulator’s questions regarding registration
  • Switch Services, from state to SEC or SEC to state

    • Prepare/amend & submit Form ADV Part 1 on the IARD system
    • Prepare/amend & submit Form ADV Part 2A and Appendix 1
    • Prepare/amend & submit Form ADV Part 2B Supplements
    • Prepare & submit Form U-4 for investment adviser representatives on the CRD system
    • Provide draft amendments to investment advisory agreements to address differences in state vs. SEC registration
    • Submit all required documentation with the SEC or State(s)
    • Respond to regulator’s questions regarding registration
    • Prepare and submit Form ADV-W to withdraw from state/SEC registration
    • Amend, update, or create written codes of ethics for differences in state vs. SEC regulations
    • Amend, update, or create written compliance policies & procedures for differences in state vs. SEC regulations
    • Provide education on the differences in state vs. SEC regulations
    • Provide training on compliance program implementation
    • Provide training on what to expect and how to prepare for a regulator audit
  • Filing for Exempt Reporting Advisers, SEC or state
 

Draft Regulatory Filings

  • ASG will act as the Service Bureau for your IARD account
  • Manage the annual updating and renewal process
  • Prepare & submit Form ADV Part 1
  • Prepare & submit Form ADV Part 2A (Brochure) and Form ADV Part 2B (Brochure Supplement)
  • Prepare & submit Form ADV Part 2A Appendix 1 (Wrap Brochure)
  • Prepare & submit Forms U-4 and U-5
  • Manage state registrations or notice filings

Creation of Customized Compliance Programs

  • Conduct risk assessment
  • Draft risk matrix
  • Prepare customized codes of ethics
  • Prepare customize written compliance policies & procedures
  • Create a customized compliance calendar
  • Create compliance forms, logs & checklists
  • Provide training on compliance program implementation
  • Provide training on what to expect and how to prepare for a regulator audit

CCO Compliance Training

  • Conduct regular consultations and training with Client regarding Client’s:
    • Code of Ethics and written Compliance Policies and Procedures;
    • Obligations under Rule 204A-1 and 206(4)-7 of the Investment Advisers Act
    • Compliance program
    • Compliance calendar used to identify important dates and regulatory deadlines
    • Recordkeeping obligations
    • Internal review requirements

Ongoing Compliance Maintenance Support

  • ASG will act as the Service Bureau for your IARD account
  • Prepare & submit amendments to Form ADV Parts 1 & 2A throughout the year
  • Prepare & submit amendments to Form ADV Part 2A Appendix 1 throughout the year
  • Prepare & submit amendments to Form ADV Part 2B supplements throughout the year
  • Prepare & submit annual updating amendment
  • Process annual renewals
  • Prepare & submit Forms U-4 & U-5 for investment adviser representatives throughout the year through CRD
  • Prepare & submit new state registrations
  • Conduct an annual review of state registration/notice filing requirements
  • Respond to questions initiated by the client for ongoing compliance matters
  • Review marketing material (incl. web site) upon request of Client
  • Provide periodic compliance updates on new regulations
  • Review & update customized compliance calendar and checklist
  • Provide various compliance templates, forms & logs from ASG’s document library
  • Update custom code of ethics and written compliance policies & procedures

Outsourced Annual Reviews

  • Review Form ADV Parts 1 & 2, investment advisory agreements, privacy policy, web site and standard marketing material
  • Review of written compliance policies & procedures and codes of ethics
  • Test compliance with written compliance policies & procedures and statutes and rules
  • Review compliance in areas noted in past regulatory deficiency letters
  • Provide a report of review findings and recommendations to achieve compliance
  • Assist client in the implementation of ASG's recommendations, providing draft amendments, as needed, to Form ADV, investment advisory agreements, codes of ethics, and written compliance policies, and creation or amendment of forms
 

Annual Review Support

  • Provide guidance to Client in conducting the internal review of its compliance program
  • Identify and recommend specific reviews and tests for the Client to conduct
  • Develop a testing schedule in conjunction with Client to identify focus areas for review
  • Provide a custom electronic workbook for Client to document testing completed
  • Conduct monthly or quarterly calls to discuss results of testing completed by Client and upcoming testing items
  • Perform testing in specific areas requested by Client
  • Provide education on Federal & State regulation to which Client is subject in areas of possible deficiency
  • Prepare a summary report of review findings and remedial action taken consistent with the requirements of Rule 206(4)-7 of the Investment Advisers Act
  • Assist Client in the implementation of ASG’s recommendations, providing draft amendments, as needed, to Form ADV, investment advisory agreements, code of ethics, and written compliance policies, and creation or amendment of forms and compliance calendar
  • Conduct risk-based analysis of firm
  • Draft a risk-matrix [delivered at conclusion of the year]

Mock Audits

  • Review Form ADV Parts 1 & 2, investment advisory agreements, privacy policy, web site and standard marketing material
  • Review of written compliance policies & procedures and codes of ethics
  • Test compliance with written compliance policies & procedures and statutes and rules
  • Review compliance in areas noted in past regulatory deficiency letters
  • Conduct a WebEx to discuss review findings and recommendations
  • Provide a report of review findings and recommendations to achieve compliance
  • Provide education on Federal & State regulation to which Client is subject in areas of possible deficiency
  • Assist Client in the implementation of ASG's recommendations, providing draft amendments, as needed, to Form ADV, investment advisory agreements, codes of ethics, and written compliance policies, and creation or amendment of forms and compliance calendar

Marketing Material Reviews

  • Review specified marketing materials such as brochures, presentation decks, newsletters, web sites, and performance advertisements for compliance with advertising regulations and guidance under the Investment Advisers Act or applicable State advertising regulations
  • Provide comments and draft suggested changes to marketing materials in areas of possible deficiency
    • ASG prefers to review materials in context and seeks to understand the intent and purpose behind the piece
    • Rather than merely pointing out items of deficiency, ASG takes the time to suggest alternative language or means of presenting an idea that conforms to regulatory guidance
  • Provide education on how to prepare compliant marketing material, including various advertising templates, forms and educational materials from ASG’s document library

Individualized Compliance Consulting

  • Provide individualized compliance consulting dependent upon Client’s needs
  • Examples of areas of consultation include, but are not limited to:
    • Buying an advisory firm;
    • Merging with another advisory firm;
    • Adding new services;
    • Adding new staff or branch offices;
    • Engaging third-party marketers; and/or
    • Launching a social media campaign
  • Consult on the compliance implications of the issue at hand and assist Client with devising and implementing new policies and controls and creating related documents
 

Regulatory Examination Support

  • Conduct call with Client at initiation of regulatory examination
  • Remain available during the examination for consultation
  • Conduct regular debriefing calls with Client during course of examination
  • Attend exit interview (ASG will not be the lead or active participant)
  • Draft or review responses to regulatory correspondence

None of the above listed services should be considered legal advice. Advisor Solutions
Group, Inc. does not provide legal advice. ASG will work together with your attorney.
Services provided by a lawyer will be at a separate cost to services provided by ASG.