RIA Policy & Procedures Manuals and Code of Ethics
Bates assists in drafting your initial manual or updates to existing manuals
Firms should use their compliance policies and procedures and Code of Ethics as the cornerstone of a robust and effective Compliance Program. Having comprehensive policies that are specific to the firm and its operations is vitally important. Many firms purchase generic, one-size fits all policy manuals that create more harm than good. Bates Compliance customizes its Compliance Manuals and Code of Ethics to fit the culture, business, operations and capabilities of your firm.
To have items listed in your manuals that don’t correspond to your firm is one of the findings in so many examinations. When you work with Bates Compliance, we take the time to understand your firm, how your firm operates and create a customized set of procedures that will both represent truly how your firm operates, but also guide your firm in how the process should be followed. Through a series of document reviews and extensive communication with the departments, your Bates Compliance consultant will be able to both capture as well as articulate the true processes of the firm.
Bates will work with the CCO to develop customized policies, procedures, and plans to reflect business practices, best practice recommendations, recent regulatory risk alerts, and new regulations.
Code of Ethics:
Rule 204A-1 requires SEC-registered investment adviser to establish, maintain and enforce a written code of ethics containing, at a minimum, a standard of business conduct that the adviser requires of its "supervised persons. Bates will help develop and, as needed update a Code of Ethics for the firm that complies with Rule 204A-1.
