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Investment Adviser Compliance

Gordian provides ongoing compliance support and project based services for Investment Advisers, Private Fund Managers, and Futures Professionals. Our consultants keep up to date on current state and federal regulatory changes and initiatives to ensure that the focus remains on relevant issues for your Investment Advisory firm.

Our services include:

    • Prepare and submit entitlement documents for access to FINRA’s IARD Web Portal
    • Prepare and submit Form ADV Part 1 and 2 for SEC and State registration
    • Register firm as a Commodity Pool Operator/Commodity Trading Adviser with the CFTC and NFA—including Forms U-10, 7R, and 8R
    • Manage FINRA IARD administration—including applicable state notice filings and registration of investment adviser representatives (Form U4s)
    • Provide guidance for additional SEC, NFA, or state requests during registration
    • Prepare and submit amendments to Form ADV as needed, and on an annual basis
    • Assess and maintain a firm’s compliance manuals, including Policies & Procedures, Code of Ethics, Privacy Policy, Business Continuity, and Disaster Recovery Plan
    • Draft and submit applicable filings for regulatory reporting: Forms 3 4 and 5, Form D, Form PF, Form 13F, Form 13H, Schedule 13D/G
    • State “blue sky” notice filings (For private fund managers)
    • Ongoing compliance training for firm employees
    • Conduct annual compliance program review and risk assessment;
    • Administer mock regulatory exam, including findings report;
    • Review procedures relating to Anti-Money Laundering compliance, best execution, trade management procedures, process for performance calculations proxy voting, vendor due diligence, gifts and entertainment, and political contributions
    • Conduct audit of necessary Books & Records
    • Review marketing materials, newsletters, websites and presentations for compliance with the Investment Advisers Act of 1940 and applicable NFA guidelines
    • Monitor employee personal trading through STAR Compliance
    • Set up email archiving processes
    • Review all documents requested by regulators
    • Provide onsite presence and support during regulatory inspections

Broker-Dealer Compliance

Gordian offers the full range of compliance services that allow broker dealers to satisfy their FINRA and state requirements while establishing best practices in anticipation of new regulations. Whether your organization needs one-time registration/audit assistance or ongoing compliance support, Gordian will ensure that your firm is prepared for any regulatory changes from the SEC or FINRA.

Our services include:

  • Draft initial New Member Application (NMA) for initial FINRA membership
  • Collaborate on preparing a Business Plan
  • Collaborate on preparing/reviewing Written Supervisory Procedures
  • File for applicable SEC or state registration
  • Manage FINRA IARD administration—including registration of principals/owners (Form U4s)
  • File completed fingerprint cards
  • Communicate with FINRA New Membership Department and any additional document requests
  • Draft and submit Change in Membership Application (CMA)
    • Develop and maintain Written Supervisory Procedures, Privacy Policy, Anti-Money Laundering Procedures, Business Continuity Plan, and Disaster Recovery Plan
    • Establish and maintain Firm Element Continuing Education and training practices
    • Provide registration services
    • FINRA Rule 3130 Certification
    • Annual Testing and verification of supervisory procedures, including: Branch/Non-Branch Office Examinations, Trade Desk Audit, Independent Anti-Money Laundering Audit, Business Continuity Testing, Sub-Advisor Diligence, Third Party Vendor Due Diligences, and Books & Records
    • Review of accounting systems, expense allocation arrangements, Focus Reports, SIPC assessments, SSOI reports, and net capital customer safeguards
    • Monitor net capital compliance
    • File FOCUS reports
    • Review all documents requested by FINRA
    • Provide onsite presence and support during FINRA inspections