Annual Program Review — Rule 206(4)-7

All SEC-Registered Investment Advisers (“RIAs”), as well as those engaging in established best practices, are required to perform an annual review of the firm’s Compliance Program. Bates will conduct the SEC required Annual Review to test and assess the adequacy and effectiveness of your policies and procedures, fulfilling the requirements under Rule 206(4)-7 of the Investment Advisers Act of 1940. Although the rule requires only annual reviews, advisers should consider the need for interim reviews in response to significant compliance events, changes in business arrangements, and regulatory developments. 

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A Bates Annual Review Consists of:
  • Introduction and Initial Firm Review
  • RIA Document Request
  • Analysis, Interviews, and Follow-up Requests
  • Report Drafting
  • Delivery of Report and Exit Interview

This service is available for a wide range of clients, from small, one-member firms to the largest in the industry. Bates can scale to deliver a review consistent with the complexity of your RIA business model. Bates annual review report will help RIAs identify areas of weakness and provide recommendations for improvements. Whether you desire a third-party review perspective occasionally or establishing an ongoing review relationship with someone who knows your RIA business model, the Bates Annual Review service is tailored to your needs.

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