Protection of Vulnerable Adults from Financial Exploitation Act
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Registration Filing Requirements
IA Compliance Materials
Deficiencies and Best Practices
Top 5 Deficiencies
Helpful Military Websites
Websites for Investors
Auction Rate Settlements
Best Practices for Investment Advisers
Prepare and maintain all required records, including financial records. Back-up electronic data and protect records. Document checks forwarded.
Review and revise Form ADV and disclosure brochure annually to reflect current and accurate information.
Review and update all contracts.
Deliver disclosure brochure initially and annually as required.
Review all advertisements, including website and performance advertising, for accuracy.
Calculate and document fees correctly in accordance with contracts and ADV.
Prepare and maintain written compliance and supervisory procedures relevant to the type of business to include business continuity plan. Assess and update periodically.
Implement appropriate custody safeguards, as applicable. Pay close attention to direct fee deduction invoices.
Keep accurate financials. File timely with the jurisdiction. Maintain surety bond if required.
Make sure client’s investment policy and suitability information are current.
Disclose soft dollars or benefits received.
Prepare and maintain current client profiles.
Review solicitor agreements, disclosure, and delivery procedures.
North American Securities Administrators Association | www.nasaa.org