Frequently Asked Questions

Why does a broker-dealer need to be SEC and FINRA compliant?

Broker-dealers are registered with the SEC and are members of FINRA, thus subject to SEC and FINRA rules. Violations of either SEC or FINRA rules carry significant consequences, including censure, fines, and reputational damage.

Why do I need financial regulatory compliance software?

Your firm’s regulatory compliance program keeps your firm functional, ensuring you meet regulatory requirements and standards of conduct, mitigating financial, reputational and regulatory consequences of a compliance violation.

In fact, financial regulatory compliance software can help you:

Automate manual, time-consuming activities, which eat away at your day and make it difficult to focus on big-picture priorities.
Determine gaps in your compliance program, which could leave you open to risk.
Report on all compliance activities, providing an audit trail for your firm and any regulatory body.
Ensure your compliance program is functioning at the optimal level.
Learn more about the benefits offered with a best-in-class software partner.

What type of customer support is provided?

Comply provides our customers with the service and support required to meet the exacting demands of the regulatory industry, while embodying the attention to detail you demand of yourself and your team. With 24/5 support and unparalleled in-house expertise, your program is our priority from the moment you begin the onboarding process. That’s our promise to you.

You can contact our Customer Support team here.

What is included in the mock SEC exam?

The Securities and Exchange Commission continues to increase its exam pace especially for those investment advisers that have not been examined within the last three years. Through our Mock SEC Examination, NRS tests your firm’s preparedness for examination. The mock examination evaluates the ability and preparedness of your firm’s key personnel, processes and records to help determine if your firm’s commitment to compliance will meet regulatory expectations.

The NRS Mock Examination is executed in three stages:

Off-Site Review: As the SEC would do, NRS expert compliance professionals request a series of compliance documents to understand the firm’s unique business practices and then use those documents to prepare for an onsite examination.

Onsite Mock SEC Exam: NRS compliance professionals visit your firm’s offices and conduct a live mock SEC Exam through a series of exercises and interviews of the firm’s senior staff and personnel. Our compliance professionals hold a wrap-up meeting and deliver feedback. Topics covered during the mock session will include Risk Management, Trading Practices, Vendor Due Diligence, Form ADV Disclosure, AML procedures and others.

Off-site Exam Report: Upon completion of the onsite review, NRS will provide a written summary of the findings and any recommendations for corrective actions, which may include follow-up training for specific individuals or the firm as a whole.

What types of companywide trends can the employee trade monitoring software help me identify?

Unlocking the power of your data is critical in spotting trends and addressing potential issues as they may arise. ComplySci’s Platform can help with:

Peer analysis reporting: Discover most frequently made trades or employees with the highest trade volumes compared to others in the firm.

Trade/request reconciliation reporting: Find employees who have traded with/without preclearance approval, as well as employees who frequently submit requests and do not execute the trade, indicating they might be fishing for information, seeing what can get approved/denied with no intention of following through with the request they submitted.

Post-trade testing: Compare employee transactions to holding period requirements, restricted trading lists and firm trades.

What kind of continuing education does ComplySci provide for broker-dealers?

As part of the Comply portfolio, ComplySci customers have access to leading continuing education programs, including the NRS IACCP courses and the RIA in a Box Investment Adviser Representative (IAR) program for those broker-dealers in state which have implemented the North American Securities Administration Association (NASAA) requirement.

What is included in the premier compliance partnership?

Compliance requires a sophisticated mix of skills, responsibilities, knowledge and personal skills not readily available in many firms, that strain resources and threaten their ability to maintain compliance.

NRS Premier Compliance Partnership services are delivered by NRS’ expert compliance professionals and;

Supplement your internal compliance teams with deep expertise that helps your firm keep pace with changing regulations, and frees up valuable, internal resources to focus on specific compliance concerns and core business activities.

Services are:

Flexible – outsource all or some of your compliance program components,
Custom – offerings are individually designed to meet specific firm needs,
Expert – highly skilled compliance professionals with extensive consulting engagement experience, and
Continual – regular, offsite compliance testing and reporting in critical risk areas.

Put the renowned expertise of NRS compliance professionals in your corner with an NRS Premier Compliance Partnership. The program bundles several products and services that, in our decades of experience, have proven most advantageous to NRS clients including

Risk Assessment & Gap Analysis
Preparation of a Tailored Compliance Calendar & Testing Matrix
Regular Offsite Compliance Testing and Results Reporting
Form ADV Annual Updating & Other-Than-Annual Updating Amendments
Dedicated Compliance Support
Compliance Education
Access to the NRS ComplianceGuardian™ Platform
Annual Reviews
Regulatory Examination Support Services

Typical Tasks include:

Monthly Email Reviews
Marketing Review
Quarterly Trade Blotter Reviews and Best Execution Testing
Semi-Annual Testing of Political Contributions
State Notice Filing/Registration
Investment Adviser Representative Licensure Verification

What is the Investment Adviser Core Compliance (IA Core) program?

Investment Adviser Core Compliance program includes 10 courses, which can then be applied towards future IACCP program requirements.

The Investment Adviser Core Compliance program provides essential training on the Investment Advisers Act of 1940 and is a stepping-stone to the IACCP Program and designation.

This program provides:

Flexible Learning, with all courses offered online and/or attend in-person events.
The opportunity to earn continuing education credits for attorneys, accountants/CPAs, certified financial planners and compliance professionals.

How is this solution customized for my firm?

The Comply Program Management platform is custom-built according to a firm’s ADV and compliance manual. Compliance tasks and guidance are tailored according to state and SEC regulation and the internal policies of your firm to provide guidance, best practices, and documentation for completing required compliance activities for the firm. Compliance tasks are also organized in a dynamic calendar to keep you and your firm up to date on required activities, changing regulation, and any firm-wide compliance requirement that needs complete.

What reporting is available for audit purposes?

The Comply Program Management platform logs firm compliance activities to our Compliance Program Reports Builder. This allows compliance teams and supervisors to generate detailed reporting on any and all compliance activities completed within the platform in the event of an audit.

How long does the onboarding process usually take?

ComplySci’s onboarding team will be there with you every step of the way, working with you to create a plan which addresses your company’s unique needs. During onboarding the team will load data, configure the system to your use case and help set up integrations. The team will also provide guided instruction of broker feed outreach and assist with establishing broker feeds. Onboarding is concluded with supervisor training and assisting your organization go live with ComplySci.

Typical onboarding takes approximately 6-8 weeks. For larger clients onboarding is scoped to meet your company’s unique needs.

How do I start the RIA registration process?

Call +1 (866) 611-7638 to learn more about the registration process and how our team of experts can help.

What is the IACCP program?

The NRS Investment Adviser Certified Compliance Professional (IACCP) Program, co-sponsored by the Investment Adviser Association (IAA), is designed for compliance professionals wanting to certify their knowledge of investment advisory regulatory obligations, and offers additional competency in trading, regulatory mandates and other current regulatory priorities.

Participants receive a compliance education based on a solid understanding of all, including the latest regulations and rules with which all investment advisers must comply. The program curriculum includes a detailed, step-by-step examination of the Investment Advisers Act of 1940 and related state and federal regulations, provides guidance for building a strong compliance program and highlights best practices which can immediately be implemented at firms.

What is a Form ADV 2B and why would a compliance professional have to file one?

Form ADV 2B is a supplement to Form ADV, which is a regulatory filing required by the SEC and state securities regulators for investment advisers. Form ADV 2B is specifically for investment adviser representatives (IARs) and provides additional information about the IARs who provide investment advice on behalf of the firm.

IARs must file Form ADV 2B with their state regulator(s) as part of their registration process. The form includes information such as the IAR’s education and business background, any disciplinary history, compensation arrangements, and other information that may be relevant to clients or regulators.

Compliance professionals may need to file Form ADV 2B on behalf of their firm’s IARs as part of their overall compliance program management. Ensuring that all required regulatory filings, including Form ADV 2B, are completed accurately and on time is an important aspect of maintaining compliance with applicable regulations.

What solutions does Comply offer for private equity firms?

With tools designed to track and monitor compliance with employee trading, gifts and entertainment, political contributions, outside business activities, and marketing materials, Comply helps mitigate risks and identify conflicts of interest. Private equity firms can optimize their compliance programs by using the ComplySci Platform, Control Room, Political Contribution Verification module, and more.

In addition Comply offers compliance consulting and continuing education services designed to help keep your firm ahead of the regulatory curve.

What types of reviews are consultants able to perform?

On-site and remote reviews include:

Compliance program review.
Annual review.
Mock SEC exam.
Independent compliance consultant review.
Anti-money laundering audit.
Cybersecurity review.

What is included in the investment adviser registration service?

Registering as an Investment Adviser with the SEC or state regulators is increasingly complex. Completing the required registration documents requires time and expertise — whether you are a sole proprietor opening your own firm or a billion dollar private fund that is no longer considered exempt.

There is no reason to do it alone. NRS compliance professionals guide investment advisers through registration as you take the steps required to establish your practice. Rely on NRS for:

Direct guidance and assistance in drafting your firm’s Form ADV documents, and SEC and state documents as required,
Development of the firm’s policies and procedures customized for your compliance program, and
Access to NRS ComplianceGuardian™, NRS’ trusted compliance platform that provides the documents and ongoing policy support required to design, implement and maintain your compliance program.

What is included in the ComplianceGuardian platform?

Firms of all sizes choose ComplianceGuardian to cover their compliance fundamentals, including:

Model Policy and Procedures and Written Supervisory Policies and Procedures (WSP).
Quarterly updates on changing policy requirements and industry guidance.
Model Documents Library.
Expert Guides and Checklists.
Annual Review Management Tool.
Attestation Management and Archiving.
Compliance Calendar and Monthly Compliance Program Workbooks.

Why use Virtual Desktop Infrastructure?

The solution is built upon the NIST information security framework, which focuses on five functions – identify, protect, detect, respond and recover. The Virtual Desktop’s Elite and Standard solutions address specific RIA compliance needs, including data backup, disaster recovery, cybersecurity and other record keeping technologies.

What is included in the cybersecurity review?

The SEC continues to emphasize that cyber security protection is critical to the operations of financial markets. In its recently released National Exam Program Examination Priorities, the Office of Compliance Inspections and Examinations (OCIE) reiterated that the Commission is focused on working with firms to identify and manage cyber security preparedness in the securities industry. NRS Cyber Security Review and our cyber security compliance professionals are here to support your efforts to remain in compliance in this challenging domain.

From emerging cyber-threats, to State and Federal mandates, CCOs must focus their time on marrying the right policies and procedures with the right technology solutions to secure the firm’s perimeter and mitigate risks. OCIE’s examinations focus, in part, on identification of risks and cyber security governance, protection of firm networks and information, risks associated with remote customer access, risks associated with vendors and third parties and detection of unauthorized activity.

Relying on the experience gained from providing custom compliance and technology services and solutions to the financial services industry, NRS offers a ‘right-sized’ approach that helps firms identify their cyber security risks: from closing the gaps that exist in a firm’s IT security infrastructure, to developing in-depth and customized cyber security policies with a focus on compliance.

NRS can deliver custom programs that help firms:

Assess Cyber security risks.
Develop the right policies and procedures.
Train staff to think compliance first.
Support the business through annual updates, reviews and strategic planning.
Test vulnerabilities and application security.
Manage the security risks with vendors and conduct the necessary due diligence.

How does PeerCompare work?

With PeerCompare, powered by Comply and InvestorCOM, you can easily generate a product peer group of available investment alternatives based on cost, risk, and return, and confidently deliver compliant recommendations while tracking all activity and relevant notes.

Which states have adopted an independent adviser representative (IAR) CE requirement?

Arkansas – Effective Jan. 1, 2023, Arkansas will require IARs to complete 12 credits to maintain registration by Dec. 31, 2023.
Colorado – Effective Jan. 1, 2024, Colorado will require IARs to complete 12 credits by Dec. 31, 2024 to maintain registration status.
Kentucky – Effective Jan. 1, 2023, Kentucky will require IARs to complete 12 credits to maintain registration by Dec. 31, 2023.
Maryland – The state has fully adopted the CE model rule. Completion of 12 credits is required by Dec. 31, 2022, to maintain registration in Maryland.
Michigan – Effective Jan. 1, 2023, Michigan will require IARs to complete 12 credits to maintain registration by Dec. 31, 2023
Mississippi – The state has fully adopted the CE model rule. Completion of 12 credits is required by Dec. 31, 2022, to maintain registration in Mississippi.
Nevada – State adoption is not finalized. If it is not finalized prior to 2022, implementation will not occur until at least Jan. 1, 2023.
Oklahoma – Effective Jan. 1, 2023, Oklahoma will require IARs to complete 12 credits to maintain registration by Dec. 31, 2023.
Rhode Island – State adoption is not finalized. If it is not finalized prior to 2022, implementation will not occur until at least Jan. 1, 2023.
South Carolina – Effective Jan. 1, 2023, South Carolina will require IARs to complete 12 credits to maintain registration by Dec. 31, 2023.
Tennessee – Effective Jan. 1, 2024, Tennessee will require IARs to complete 12 credits to maintain registration by Dec. 31, 2024.
Vermont – The state has fully adopted the CE model rule. Completion of 12 credits is required by Dec. 31, 2022, to maintain registration in Vermont.
Washington D.C. – Effective Jan. 1, 2023, Washington D.C. will require IARs to complete 12 credits to maintain registration by Dec. 31, 2023.
Wisconsin – Effective Jan. 1, 2023, Wisconsin will require IARs to complete 12 credits to maintain registration by Dec. 31, 2023.

How do I get the most out of my financial regulatory compliance software?

Every dollar matters during a period of economic downturn. This makes prioritizing your spend essential to keeping your financial advisory firm at peak of performance, investing where appropriate for long-term success while not over-reaching and potentially overspending.

Work with the right compliance technology partner.
Prioritize your fiduciary education.
Bring in outside help as needed.
Create a culture that prioritizes compliance.
Lean into your *free* resources.

Read more about the economic benefits of a strong compliance software partner.

Who would need registration support?

Broker-dealer breakaways – Those who were previously affiliated with a wirehouse or independent broker-dealer and are breakaway to establish a fee-only RIA firm or to start a hybrid firm by maintaining an affiliation with an independent broker-dealer.
Financial planners – Advisers looking to provide financial planning services and who may or may not also provide in-house or outsourced investment advisory services.
Independents advisers – Advisers already serving as a fiduciary with an RIA firm who are seeking more independence by establishing their own RIA firm.
Internet only robo advisers – Firms looking to provide automated online investment advice.
Investment managers – Firm or portfolio managers looking to provide investment management services to individuals or institutions such as other RIA firms.
Private fund managers – Private equity, hedge fund, venture capital or other alternative fund managers who need to register as an RIA or exempt reporting adviser (ERA).

Considering starting a your own RIA firm? Download The Ultimate New Registration Toolkit to help you navigate the intricacies of registration… from start to finish!

What is included in the anti-money laundering audit?

New ways to launder money and engage in fraudulent activities have put broker dealers under increased pressure to remain compliant. The USA Patriot Act and FINRA Rule 3310, require broker dealers and dually-registered firms to design and implement an AML program that includes appropriate policies and procedures, a customer identification program, and an annual review of the firm’s policies and procedures.

NRS audits a firm’s AML program to determine if it is compliant with FINRA rules and the USA Patriot Act. Working with key stakeholders at your firm, NRS expert compliance professionals conduct an onsite review and test of your firm’s AML program and related policies and procedures. NRS delivers a report addressing firm’s program soundness. This allows broker dealers and dually-registered firms to meet annual requirements as outlined by FINRA for an independent AML program review.

NRS expert compliance professionals:

Review and test the AML written supervisory policies and procedures.
Review client files with an emphasis on foreign clients.
Review and test internal surveillance practices.
Review the AML training plan for all appropriate personnel.
Review for required AML documentation.
Deliver a written report highlighting deficiencies and recommending appropriate corrective measures.

Are there specific compliance solutions for independent registered investment adviser (RIA) firms?

Yes, Comply offers various RIA firm-specific software and services, including RIA registration, compliance support, employee supervision, and cybersecurity.

What solutions does Comply offer for institutional investors?

Comply offers various solutions for institutional investors to streamline their compliance tasks and efficiently meet the Securities and Exchange Commission’s (SEC) requirements. Learn more about our solutions, including the ComplySci Platform and Control Room.

What is included in the compliance program review?

NRS Compliance Reviews help firms stay ahead of ever-changing FINRA, SEC and State Regulations. Our expert consultant compliance professionals execute a comprehensive assessment of your firm’s compliance program, test it against applicable regulatory requirements and expectations, and help identify and remediate compliance risks.

NRS conducts a thorough review with an emphasis on policies and procedures, regulatory requirements, and industry best practices to prepare firms for a regulatory examination, and to identify compliance risks. Reviews are tailored to fit your needs and include:

Anti-Money Laundering Audit
Risk Assessment
Due Diligence Review
Cybersecurity Review

NRS consultant compliance professionals have decades of expertise working in the private sector and for regulatory bodies. They bring unmatched expertise when reviewing your firm’s compliance procedures while navigating regulatory requirements and considering real-world business needs.

What is Comply?

Comply is the parent brand under with ComplySci operates.

Along with RIA in a Box, NRS and illumis, the Comply portfolio of firms is the champion for compliance professionals and the meticulous, detail-oriented perfectionists who make up their teams. Together, these firms lead the market with the solutions and expertise necessary to tackle core compliance challenges head-on and stay up-to-date with the ever-changing regulatory landscape. At Comply, we are an extension of our clients, driving effective compliance programs with precision and accuracy.

Will Comply's solutions help UK compliance teams meet the Financial Conduct Authority's (FCA) regulations?

Yes, Comply offers solutions to help firms meet a wide variety of regulations globally, including the FCA. Comply’s SMCR Module is designed to help regulated firms facilitate and manage the requirements of the FCA’s senior managers and certification regime. This allows firms to easily capture senior management functions and responsibilities through the creation and distribution of digital SMCR forms. You will also have the ability to manage and maintain further requirements from the FCA regarding statement of responsibilities, fitness and propriety assessments, consumer duty reporting and conduct rules training and monitoring.

How can I schedule a demo?

Complete this form to schedule a full demo and see firsthand what our compliance solutions can do for you.

BOOK A DEMO

What additional services are available?

We can assist our clients with these additional RIA regulatory filings:

Form 13F: For firms that exercise investment discretion with respect to $100 million or more in 13(f) securities.
Form PF: For private equity and hedge fund advisers managing at least $150 million in private fund assets under management.
Form 13H: For large traders registering with the SEC.

We also provide virtual mock audit services for RIA Firms:

Virtual Mock Audit: Conducted by a former regulator and includes a virtual review of files including Form ADVs, books and records, policies and procedures, and advertising materials.

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