We take the guess work out of meeting the initial regulatory requirements. Focus 1 will work with your compliance / management team to provide assistance with the following:

  • ADV Parts 1 & 2A filing
  • ADV Parts 2A and 2B development
  • Code of Ethics development, in accordance with Rule 204A-1 of the Investment Advisers Act and 17j-1 of the Investment Company Act of 1940
  • Policies and Procedures development, in accordance with the areas the SEC has identified in the adopting release of Rule 206(4)-7 as applicable to your firm:
    • Portfolio Management
    • Accuracy of Disclosures
    • Proprietary Trading
    • Safeguarding of Client Assets
    • Books and Records
    • Safeguards for Privacy Protection
    • Trading Practices
    • Marketing Advisory Services, Including Solicitation
    • Valuation of Client Holdings and Assessment of Fees
    • Business Continuity Plans

Note: FOCUS 1 will address any additional procedures deemed necessary such as Proxy Voting, Political Contributions and Identity Theft / Red Flags rules.

  • New Adviser Examination Request Letter review, to ensure your firm is ready and able to provide the necessary documents.