|Compliance Exam Materials
A. Documents required for all investment advisers:
- A copy of the most recent Form ADV, Part 2 and any disclosure document given in conjunction with or in lieu of Part 2.
- A copy of the standard advisory contracts or agreements.
- All promotional brochures, pamphlets, and other advertising materials furnished to clients or prospective clients within the past 12 months (e.g. seminar
materials, newsletters, newspaper advertisements, business cards, letterhead).
- Written supervisory policies and procedures.
- Complete complaint, arbitration and litigation files.
- Any performance reports, data or graphs that are currently disseminated to clients or prospective clients along with the records and work papers supporting
the claims contained therein.
- All accounts, books and internal working papers that form the basis of any performance or rates of return that are used in any advertisements.
- A list of all personnel including their titles, CRD numbers, professional designations, and employment dates.
- A list of all parties who have been paid cash referrals during the last three years.
- Records evidencing the offer or delivery of the IA's disclosure brochure or Part 2 of the ADV, as well as copies of the disclosure documents delivered to
clients by solicitors.
- A list of current clients under contract and the type of service provided to them. The list should include the current value of each account and whether
the IA has discretionary authority over the account.
- All documents granting discretionary trading authority over client assets.
- All written authorizations from clients granting authority to third parties.
- A list of clients that terminated the IA's services during the previous 12 months and the reason for termination.
- A list of all clients directly or indirectly related to any of the IA's affiliated/related persons. The list must show the names of the clients and the
parties to whom they are related.
- A list of clients who have instructed the IA to direct brokerage business to a particular broker-dealer. This list should include the name of the broker-
dealer and the client's reason for such directions, if known.
- A list of broker-dealers affiliated with the IA and/or any of the IA's related persons.
- Copies of the current written agreements concerning any soft dollar arrangements.
- Separate ledgers and journals reflecting the trading in client accounts conducted in order to satisfy the soft dollar commitments.
- A list of clients for whom financial plans were started or completed in the prior 12 months. This list should include the fee charged for each plan and the
dates the plan was started and completed.
- Currency Transaction Reports that have been filed with the IRS.
- A list of all investment partnerships, trusts, and any other pooled investment vehicle created, offered, or managed by the IA or any associated persons to
clients or prospective clients.
- All offering memoranda, financial statements and agreements, as applicable for all investment partnerships,
trusts, and any other pooled investments along with all reports sent to the limited partners for the prior 12 months.
- A record of every transaction in a security in which the IA or any associated persons have any direct or indirect beneficial ownership.
- Minutes of the board of directors' meetings, articles of incorporation, corporate bylaws, and stock transfer records or partnership agreements, where
- Journals or summary journals.
- General and auxiliary ledgers.
- All check books, bank statements, canceled checks, credit card statements and cash reconciliation documents.
- Trial balances, financial statements and internal audit papers.
- All bills and statements, whether paid or unpaid.
- Order memoranda.
- The brokerage account statements and order tickets for all proprietary trading and investment accounts.
- Employees' personal securities transactions reports.
B. Additional Documents required if the IA has custody of customer funds or securities:
- All documents executed by clients authorizing the IA to withdraw client funds or securities upon instruction to the custodian(s).
- Records showing all purchases, sales, receipts and deliveries of securities and all debits and credits in accounts for which the IA has custody.
- A separate ledger of accounts for each custodial client showing purchases, sales, receipts and deliveries of securities.
- Copies of confirmations of all transactions effected by or for the account of any client.
- For each security in which a custodial client holds a position, provide a record reflecting:
- client name(s);
- the date(s) that each client purchased and/or sold the security;
- the number of shares currently owned by each client; and
- the physical location(s) of each client's security.
- A copy of each of the client's quarterly account statements, as generated and delivered by the qualified custodian. If the IA also generates a statement
that is delivered to the client, provide access to copies of the statements along with the date the statements were sent to the clients.