Investment adviser annual compliance review

SEC · Annually · At least once a year

Rule 206(4)-7 requires an SEC-registered investment adviser to review, no less often than once a year, whether its compliance policies and procedures are adequate and how effectively they're implemented (17 CFR 275.206(4)-7(b)). The rule sets no date, so you choose when.

What the rule requires

Written policies and procedures reasonably designed to prevent violations of the Advisers Act and its rules, by you and your supervised persons
A review of their adequacy and the effectiveness of their implementation, at least once a year
A chief compliance officer, who is a supervised person, responsible for administering them

Keep the records

Keep a copy of the policies and procedures in effect now and at any time in the past five years, and any records documenting each annual review (17 CFR 275.204-2(a)(17)). They're what an examiner asks for first.

Picking a date

Many advisers time the review so it finishes before the Form ADV annual amendment, so anything it changes can go into the brochure. Set the same date each year and it's easy to show the review happened at least annually.

Also on the calendar

Your code of ethics needs annual holdings reports and quarterly transaction reports from access persons.

Get reminded before it's due

Regmindr tracks this alongside the rest of your compliance calendar, and emails your team before each deadline.

Set up your compliance calendar See pricing

Sources

This page is a summary, not legal or regulatory advice. The rules in the sources above take precedence.