Ongoing Compliance Support for Registered Investment Advisers
Experienced Compliance Support From Former SEC Examiners and Exam Managers
ClearView provides ongoing compliance support to SEC-registered investment advisers that need experienced assistance without necessarily adding full-time internal resources. Our former SEC examiners and exam managers can supplement an existing compliance function, assist a chief compliance officer, or provide broader compliance support based on the firm’s business, regulatory obligations, and needs.
Flexible Compliance Support
Not every adviser needs the same level of compliance support. ClearView structures ongoing engagements around the firm’s business activities, regulatory risks, existing personnel, and internal resources rather than applying a one-size-fits-all compliance model.
Some firms need additional resources for specific responsibilities or projects, while others benefit from broader ongoing assistance across their compliance program. ClearView can tailor the engagement to supplement the firm’s existing compliance function and provide practical support where it is needed.
Areas We May Support
Compliance Program Administration
Assist with the ongoing administration of the firm’s compliance program, including compliance calendars, recurring obligations, documentation, and follow-up on identified issues.
Compliance Testing
Perform risk-based testing of selected policies, procedures, controls, disclosures, and business practices to evaluate whether the compliance program is operating as intended.
Annual Compliance Review Support
Assist with planning, testing, documentation, and remediation associated with the firm’s annual compliance review.
Form ADV and Regulatory Filings
Assist with Form ADV amendments, regulatory disclosures, and other recurring investment adviser filing obligations within the agreed scope of the engagement.
Policies and Procedures
Review and update compliance policies and procedures to reflect changes in the firm’s business, regulatory obligations, and compliance practices.
Marketing Rule Compliance
Provide ongoing review and compliance support for advertisements, performance presentations, testimonials, endorsements, third-party ratings, and related marketing practices.
Regulatory Developments and Compliance Updates
Help the firm evaluate relevant regulatory developments and consider appropriate updates to policies, procedures, disclosures, testing, or other compliance practices.
Remediation and Examination Readiness
Assist with addressing identified compliance issues, implementing remediation, and maintaining readiness for a potential SEC examination. If an examination begins, ClearView can also provide support throughout the examination process.
When Ongoing Compliance Support May Be Useful
Ongoing compliance support can be useful when a firm needs additional experience, capacity, or an independent perspective without necessarily expanding its internal compliance staff.
When the Compliance Team Needs Additional Capacity
Provide experienced support for recurring responsibilities, testing, projects, or periods of increased workload.
When the Firm Is Growing or Changing
Assist with compliance implications associated with new business activities, personnel, services, products, operational changes, or other developments affecting the compliance program.
When Issues or Remediation Need Additional Attention
Provide additional resources for identified compliance issues, remediation projects, testing, documentation, or follow-up.
When the CCO Needs an Experienced Resource
Serve as an additional compliance resource for recurring questions, regulatory developments, program enhancements, and specialized projects.
Ongoing Compliance Support May Include
Depending on the scope of the engagement, ongoing compliance support may include the following:
Compliance Calendar and Work Plan
A practical schedule of recurring compliance responsibilities, testing, filings, reviews, and other agreed activities.
Compliance Testing and Documentation
Documented testing and observations regarding selected compliance controls, policies, disclosures, and business practices.
Regulatory Filing Support
Assistance with applicable Form ADV amendments and other agreed regulatory filing responsibilities.
Policy and Procedure Updates
Recommended updates to written policies and procedures based on business changes, regulatory developments, testing, or identified issues.
Findings and Remediation Tracking
Identification and tracking of compliance issues, recommendations, and agreed remediation steps.
Ongoing Compliance Guidance
Practical support for recurring compliance questions, projects, regulatory developments, and program enhancements within the engagement scope.
Flexible Engagement Models
ClearView engagements can range from targeted recurring assistance to broader ongoing compliance support depending on the firm’s needs and internal resources. The scope can be adjusted as those needs change. In appropriate circumstances, more comprehensive arrangements, including fractional or outsourced CCO support, may also be considered.
Former SEC Examination Experience
ClearView’s team includes former SEC examiners and exam managers with decades of experience conducting, supervising, and managing examinations of investment advisers and evaluating compliance programs.
That experience gives us a practical understanding of how policies, disclosures, controls, testing, documentation, and remediation may be evaluated during an SEC examination. We apply that perspective to help advisers maintain compliance programs that reflect their actual business and regulatory responsibilities.
Related ClearView Services
ClearView offers a range of complementary compliance services for registered investment advisers.
Annual Compliance Reviews
Risk-based annual compliance reviews designed to identify compliance risks, gaps, and remediation priorities.
Learn moreMock SEC Examinations
Test the firm’s compliance program, disclosures, controls, and practices before an actual SEC examination.
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 morePolicies and Procedures Development
Development and enhancement of compliance policies and procedures tailored to the firm’s business and regulatory obligations.
Learn moreRIA Registration & Form ADV Support
Assistance with investment adviser registration, Form ADV filings and amendments, regulatory disclosures, and related filing requirements.
Learn moreNeed Additional Compliance Support?
Talk with a former SEC examiner or exam manager about your firm’s compliance needs and how ClearView can supplement your existing compliance resources.