Compliance Review and Advisory Platform Due Diligence Implemented at Integrated
Integrated, a leading investment advisory firm, has implemented a comprehensive compliance review process to ensure its written policies and procedures are adequate, effective, accurate, and up-to-date. This process is led by the Chief Compliance Officer (CCO) and includes an assessment of risk areas for the firm, reviews of any changes in advisory services, client base, or regulatory developments.
Annual Review of Advisory Platforms
Integrated conducts an annual review of its advisory platforms to determine if they should remain on the product shelf. This review involves assessing the sponsor’s most recent SSAE 16 report, if applicable.
Due Diligence on New Advisory Platforms
Before making new advisory platforms available to Investment Adviser Representatives (IARs), Integrated conducts due diligence to ensure that they are well-established and respected money managers with a long operating record. The firm also engages with third-party asset managers (TAMPs) as solicitors to these organizations, ensuring that they are reputable and trustworthy.
Recordkeeping Requirements
Integrated maintains records regarding due diligence conducted on advisory platforms for six years, demonstrating its commitment to transparency and compliance.
Investment Adviser Registration and Reporting
As a registered investment adviser with the SEC, Integrated has assets under management exceeding $100 million. The CCO or designee is responsible for verifying registration and reporting requirements, ensuring that the firm remains compliant with all relevant regulations.
Form ADV Filing and Updating
Integrated files Parts 1A and 2A with the SEC and applicable state regulatory authorities, maintaining a Part 2B “Brochure Supplement” for all IARs. The firm updates Part 1A annually within ninety days of its fiscal year end and maintains copies of all filings made with the SEC.
Disclosure of Disciplinary Information
Integrated discloses promptly to clients any disciplinary event that is material to an evaluation of the investment adviser’s integrity or ability to meet contractual commitments. If changes to Item 9 of Part 2A are necessary, the firm files an interim amendment with the SEC and provides it to existing clients.
The implementation of these measures demonstrates Integrated’s commitment to compliance, risk management, and transparency in its advisory services. By conducting regular reviews and due diligence, Integrated ensures that its clients receive the highest level of service and protection possible.