US Investment Advisers Act of 1940 and SEC Adviser Rules (17 CFR Part 275)
Sections 206 to 208 and the section 206(4) rules: antifraud, principal trades, marketing, custody, pay to play, proxy voting, compliance programmes, pooled vehicles – US Investment Advisers Act of 1940 and SEC Adviser Rules (17 CFR Part 275)

US Investment Advisers Act of 1940 and SEC Adviser Rules (17 CFR Part 275) 206-4-7-compliance: Adopt written compliance policies, review their adequacy at least annually and designate a chief compliance officer

Rule 206(4)-7 deems it fraudulent for a registered adviser to provide advice unless it has adopted and put into effect written procedures that can reasonably be expected to prevent breaches of the Act and rules by the firm and the people it supervises, reviews them no less than annually for adequacy and effectiveness, and designates a chief compliance officer responsible for administering them. The SEC's adopting release names the areas the policies should address: portfolio management, trading, proprietary and personal trading, accuracy of disclosures, safeguarding client assets, record-keeping, marketing, valuation and fees, privacy and business continuity. The annual review documentation is a rule 204-2 record, and the SEC has proposed requiring a written annual review report.

Maintained by Gerard Blokdyk

Other controls in Sections 206 to 208 and the section 206(4) rules: antifraud, principal trades, marketing, custody, pay to play, proxy voting, compliance programmes, pooled vehicles – US Investment Advisers Act of 1940 and SEC Adviser Rules (17 CFR Part 275)

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