SEC Rule 206(4)-7 under the Investment Advisers Act of 1940 requires every registered investment adviser (RIA) to adopt and implement customized written compliance policies and procedures, review them at least annually, and designate a Chief Compliance Officer (CCO).
Service Description: Preparation of Legal Documents for Written Policies and Procedures (Rule 206(4)-7) for a Registered Investment Adviser
Syndicate Legal Advisory Services provides nationwide legal document preparation services for Registered Investment Advisers required to prepare written policies and procedures under Rule 206(4)-7 of the Investment Advisers Act of 1940 (the Compliance Rule). We prepare the written compliance policies and procedures and related supporting materials based on the firm’s business operations, risk areas, and specific instructions you provide.
Documents Commonly Prepared
We prepare a full range of documents associated with Rule 206(4)-7 written policies and procedures, including but not limited to:
Compliance Policies and Procedures Manual: Formatting of the written policies and procedures reasonably designed to prevent violations of the Advisers Act and related rules by the adviser and its supervised persons, covering areas such as portfolio management, trading practices, personal and proprietary trading, disclosures, safeguarding of client assets, recordkeeping, marketing, conflicts of interest, and other relevant topics to the extent applicable, based on the content and descriptions you supply.
Chief Compliance Officer Designation: Preparation of materials designating the Chief Compliance Officer (a supervised person) responsible for administering the policies and procedures, based on the information you provide.
Annual Review Documentation: Formatting of materials documenting the annual review of the adequacy of the policies and procedures and the effectiveness of their implementation, based on the review details you supply.
Related Supporting Materials: Organization of exhibits, procedures, checklists, or attachments incorporating client-supplied operational details or other materials referenced in the policies.
Updates and Amendments: Formatting of updates or amendments to the policies in response to business changes, regulatory developments, or review findings, based on the revised information you provide.
Documents are prepared for the firm’s internal use and implementation as required by Rule 206(4)-7 (subject to the information you provide). The rule requires adoption and implementation of written policies and procedures, designation of a CCO, and an annual review of their adequacy and effectiveness; clients remain fully responsible for ensuring the policies are reasonably designed and tailored to the firm’s business, implementing them effectively, conducting the annual review, maintaining required records, and compliance with all Investment Advisers Act and SEC requirements.
