IA Compliance: The Full 360° View East
March 21-23 | Washington, D.C.

IA Compliance: The Full 360° View Midwest
June 25 | Chicago, IL
Conquering Current Compliance Challenges
Mar. 7, 2018 | 2:00 - 2:30 PM EST

FinTech: What It Is and How Its Promise Will Affect You Going Forward
Mar. 27, 2018 | 2:00 - 3:00 PM EST
CLE/CPE Approved 
 
RECORDED WEBINARS

Conquering Current Compliance Challenges
Recorded: Feb. 7, 2018 
 
Your Complete Guide to the New Form ADV
Includes: 20 Best Practices, 6 Peer-tested Tools and a 60-minute Webinar 

The SEC Examinations Priorities Handbook
Includes: 28 Best Practices, 20 Document Request Letters and 6 OCIE Risk Alerts

Cybersecurity Strategies to Ensure SEC Compliance, 2nd Edition
Includes: 24 Best Practices, 16 Tools, 4 Risk Alerts and IM Guidance
BOOKS AND RECORDS OVERVIEW
Advisers Act Rule 204-2 – the books and records rule – is the longest in the act at more than 4,000 words. It’s also among the oldest rules.
 
This can give firms fits because a rule written more than 50 years ago doesn’t always clearly correspondent to a world that’s now measured in bytes and bites.
 
A transparent obligation under the rule, though, is to maintain “not less than” the last five years of key records, and the two most recent years of these record “in an appropriate office of the investment adviser.”
 
The rule goes into depth about what types of records must be kept. They include bills and statements, written client communications, advisory agreements, among others. It’s worth noting that records used to construct past performance should be maintained regardless of how old they are – so that a firm can proof to examiners the veracity of its calculations.
 
Relevant books and records must be “true, accurate and current.” Firms that find themselves cited in enforcement cases tied to this rule often keep sloppy records, can’t locate or produce them or falsify them.

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