Services
A La Carte Services
Focus 1 will conduct a detailed review and assessment of pertinent compliance documents, checking for: The documents we review include your firm’s: Focus 1 identifies potential risk areas and/or conflicts of interest, while confirming the appropriateness of your annual review program. We provide comments and/or recommendations necessary to strengthen those areas needing improvement. Our comments are populated directly into your documents, creating a redline version for discussion and further development. Our Compliance Training is fully customizable to meet your firm’s needs. These recorded or live, remote training sessions cover topics of your choice and are provided at a frequency to meet your firm’s compliance training needs (e.g. quarterly, semi-annual, or annually). The information covered can be personalized to reflect your firm’s policies and procedures on the selected topics. We also offer follow-up quizzes to test the effectiveness of the training, as well as your employees’ comprehension. What makes our approach different from other firms is: Please contact us to schedule a complimentary call to discuss how team “O’Connor Davies/Focus 1” can perform a SEC Cybersecurity Readiness Assessment on your firm. Focus 1 will conduct a complete review of the firm’s marketing and advertising materials to help ensure compliance with regulatory requirements, including Rule 206(4)-1 under the Advisers Act, the disclosure requirements under GIPS, and industry best practices. Our review may include all types of presentation materials, such as pitch books, flash reports, investment commentary, newsletters, RFP’s, websites, and consultant databases. This can be accomplished on site or remotely using our secure online Portal. As part of this service, the following information will be referenced and made available: As an extension to this service, we can also compare to ADV Part 2 and/or RFP to ensure consistency. Additional fees will be assessed. With today’s heightened regulatory environment, Focus 1 will underscore the value of compliance in helping to mitigate risk. We will showcase the SEC’s current Examination Priorities as part of the National Examination Program, and just as important, discuss how best to prepare for and manage an examination. A focused discussion with compliance and senior management will include: A Compliance Training session with an online quiz to help confirm your staffs understanding of the key concepts. Mock interviews will be conducted, with a focus on key areas within your firm: In addition, Focus 1 will provide: The Third-Party Compliance Review is an independent review of your firm’s annual compliance program, looking for completeness in the program, consistency across documentation, and adherence with the Investment Advisers Act of 1940 and the rules promulgated thereunder. We perform an initial review and analysis of the information provided by your firm in order to select samples, request additional information, and identify individuals to interview while on site. This initial preparation will allow us to make more efficient use of the time spent in your office reviewing books and records. Our office visits can range from one to three days. Subsequent to the completion of the review, we provide a report containing comments and any suggestions for strengthening your firm’s compliance manual and/or compliance controls, including practices identified as “industry best practice.” The entire review will concentrate on those areas that the SEC has identified as the major areas of focus in the adopting statement to Rule 206(4)-7 and current focus areas, when applicable. These focus areas may include: For a period of up to three months following the review, Focus 1 will provide investment adviser consulting services related to the areas covered in the review and continued access to our publications and presentations, including: Compliance Documents Review & Gap Analysis
Compliance Training
Cybersecurity Readiness Assessment
With core areas of focus covering cybersecurity governance, risk assessment, protection, detection of unauthorized activity, and reporting, many firms have not had the time or resources to adequately go through the SEC’s sample request list and understand exactly what controls and documentation the SEC is expecting when conducting a firm-wide cybersecurity examination. In addition, many firms might not understand what a true cybersecurity program consists of and how to develop a security program that not only meets the SEC requirements but protects the firm’s sensitive information assets. O’Connor Davies and Focus 1 have partnered to help address both regulatory and low-level cybersecurity concerns to ensure the OCIE requirements are reasonably met.
Marketing & Advertising Review
Our typical discussion with marketing and compliance personnel will include:
SEC Exam Readiness Assessment
Third-Party Compliance Review