Annual Compliance Reviews for Registered Investment Advisers
ClearView conducts annual compliance reviews for SEC-registered investment advisers. Our former SEC examiners and exam managers provide an independent, risk-based review designed to identify compliance gaps, testing weaknesses, and remediation priorities before they become examination issues.
Independent Annual Compliance Reviews From an SEC Examination Perspective
SEC-registered investment advisers are required under Rule 206(4)-7 of the Investment Advisers Act of 1940 to review, no less frequently than annually, the adequacy of their compliance policies and procedures and the effectiveness of their implementation. The annual review is a foundational obligation of an adviser’s compliance program and a common area of focus during SEC examinations.
ClearView performs practical annual compliance reviews drawing on decades of SEC examination experience. Rather than applying a generic checklist, we approach each review from an SEC examination perspective, focusing on the areas most likely to receive scrutiny and on whether the firm’s written policies, disclosures, and actual practices are consistent with one another.
Our objective is straightforward: help your firm identify compliance risks and remediation priorities before they become examination findings.
A Risk-Based Approach to Annual Compliance Reviews
The scope of each annual review is tailored to the firm’s business model, activities, conflicts, disclosures, and areas of regulatory focus.
ClearView also assists SEC-registered private fund advisers with annual compliance reviews tailored to their investment strategies, conflicts, disclosures, and operational models.
The following areas are commonly reviewed as part of a Rule 206(4)-7 annual compliance review.
Compliance Program Governance and Oversight
Review of the firm’s compliance program structure, CCO responsibilities, reporting lines, supervision of personnel and service providers, and processes for escalating and addressing compliance issues.
Policies and Procedures
Evaluation of written policies and procedures for adequacy, effectiveness, and alignment with the firm’s actual business activities.
Compliance Testing
Evaluation of selected compliance controls and processes to assess whether the firm’s policies and procedures are being implemented and operating as intended.
Code of Ethics
Review of code administration, personal trading controls, access person reporting, and related recordkeeping.
Conflicts of Interest
Identification, disclosure, mitigation, and ongoing management of material conflicts across the firm’s business.
Proxy Voting
Where applicable, review of proxy voting policies, disclosures, practices, and supporting documentation for consistency with the firm’s stated approach.
Fees and Expenses
Review of fee calculations, allocations, offsets, and consistency with governing documents and client disclosures.
Custody
Review of custody arrangements, related disclosures, and compliance with applicable custody requirements, including identification of circumstances that may result in an adviser having custody of client assets.
Form ADV, Regulatory Filings, and Client Disclosures
Review of Form ADV, other regulatory filings, and client disclosures for accuracy, consistency with the firm’s actual practices, and alignment with applicable regulatory requirements.
Marketing Rule Compliance and Advertising Review
Review of advertisements, performance presentations, testimonials, endorsements, and related disclosures for compliance with the SEC Marketing Rule, including accuracy, substantiation, and required disclosures.
Trading, Best Execution, and Allocation Practices
Review of brokerage and trading practices, best execution processes, trade allocation methodologies, related conflicts, and consistency with client disclosures and firm policies.
Books and Records
Review of recordkeeping, retention, and production readiness across required communications and supporting documentation.
Former SEC Examination Experience Applied to Your Compliance Program
ClearView was founded by former SEC Division of Examinations professionals who conducted investment adviser examinations and evaluated compliance programs firsthand. That experience informs how we approach an annual compliance review, not as an abstract exercise, but from the perspective of professionals who evaluated whether adviser compliance programs were reasonably designed and operating effectively.
We focus on what matters from an SEC examination perspective: identifying potential deficiencies, evaluating whether policy matches practice, and providing practical remediation recommendations that a firm can actually implement.
SEC Examination Perspective
Reviews conducted from the perspective of professionals who have evaluated adviser compliance programs at the SEC.
Identifying Deficiencies
Focus on the types of issues examiners are most likely to identify and develop during an examination.
Practical Remediation Recommendations
Clear, actionable recommendations for addressing identified issues rather than generic observations.
Improving Examination Readiness
Strengthen the compliance program so the firm is better positioned for its next SEC examination.
Why Firms Use an Independent Annual Compliance Review
An independent annual review can provide additional perspective, testing capacity, and regulatory experience beyond the firm’s day-to-day compliance process.
Independent Perspective
Bring an outside perspective to policies, testing, disclosures, controls, and business practices that internal personnel work with every day.
Additional Compliance Capacity
Supplement the CCO and compliance team when the annual review requires additional testing, documentation, or experienced compliance resources.
Identify Issues Before an Examination
Surface potential compliance weaknesses while the firm still has an opportunity to evaluate and address them.
Former SEC Examination Experience
Apply the perspective of professionals who have conducted and supervised investment adviser examinations and evaluated compliance programs firsthand.
Annual Compliance Review Deliverables
ClearView’s annual compliance review is designed to produce clear, practical outputs that help management and the chief compliance officer understand identified issues and prioritize remediation.
Review of Policies and Procedures
A practical assessment of the firm’s written compliance policies and procedures, evaluated from an SEC examination perspective.
Compliance Testing
Risk-based testing of key policies, controls, and processes to evaluate whether the compliance program operates as designed in practice.
Identification of Compliance Gaps
Clear identification of areas where policies, procedures, disclosures, or practices may not meet regulatory expectations.
Written Findings and Observations
Documented findings and observations explaining what was identified and why it may matter from an examination perspective.
Recommended Remediation Steps
Practical, prioritized recommendations for addressing identified issues and strengthening the compliance program.
Annual Review Memorandum
A written summary of the review scope, testing performed, findings and observations, and recommended remediation steps to document the firm’s annual compliance review.
Related ClearView Services
ClearView offers a range of complementary compliance services for registered investment advisers.
Mock SEC Examinations
Risk-based mock SEC examinations designed to identify potential compliance issues and help firms prepare for regulatory scrutiny.
Learn moreSEC Examination Support
Support during an actual SEC examination, including document production, interviews, responses, potential findings, and remediation.
Learn moreMarketing Rule & Advertising Reviews
Independent review of advertisements, performance presentations, testimonials, endorsements, third-party ratings, and related Marketing Rule compliance practices.
Learn moreOngoing Compliance Support
Ongoing compliance assistance for RIAs, including testing, filings, policy updates, remediation, and support for the firm’s compliance function.
Learn morePolicies and Procedures Development
Development and enhancement of compliance policies and procedures tailored to the firm’s business activities, regulatory obligations, and compliance risks.
Learn moreRIA Registration & Form ADV Support
Assistance with investment adviser registration, Form ADV filings and amendments, regulatory disclosures, and related filing requirements.
Learn moreStrengthen Your Annual Compliance Review Process
Talk with a former SEC examiner or exam manager about an independent annual compliance review tailored to your firm’s business, regulatory risks, and compliance program.