1. Compliance Manual Update Staff Requirements Check
Risk Management – Compliance Manual Update
Form ADV
Update
Compliance Manual Update
Staff Requirements Check
Description: This workflow describes all the steps required to update the firm’s compliance manual, either on an annual basis or if there is a material change that requires updating right away. This is an important part of management’s role in ensuring the firm remains compliant.
Process Checklist
PREPARE
ROLE
TASK
DETAILS/TIPS
Advisor
Review Manual Against Regulatory Changes
Review any compliance notifications the firm might have received
Research any regulatory changes or news
Take this opportunity to read all the facts and reasoning behind the change to gain a deeper understanding of how this affects the firm
Identify Content to be Updated & Edited
Identify a comprehensive list of rule changes that need to be considered when updating the manual
Interpret what each change means for the firm to the best the firm’s ability
If necessary, reach out to any compliance or legal representatives for a third-party opinion on how these rules should be applied to the firm
Process Checklist
CONDUCT
ROLE
TASK
DETAILS/TIPS
Advisor
Update Compliance Manual
Review the firm’s compliance manual against this list of regulatory changes
Identify the content within the manual that must be updated and edited
Best practice is to track those changes throughout the review before making any final edits, so the firm can assess all the changes in totality in case some edits affect other language in the manual
Make all updates to the manual and proofread as appropriate
File the updated compliance manual internally for record-keeping purposes
Process Checklist
FOLLOW-UP
ROLE
TASK
DETAILS/TIPS
Advisor
Distribute Manual Internally & Notify Team
Distribute the updated compliance manual to the team and notify them of all the changes that have been made
Be as specific as possible when identifying the changes so there’s no room for confusion or oversight
Train the team on the updated compliance manual as appropriate
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