Sample Annual Review
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1 Sample Annual Activity ed Taken/ Compliance Department 1 Compliance Arrangements - - Compliance Resources - Compliance Reporting Structure - Compliance Training - Compliance Manual Updates - Annual of Compliance Policies and s 2 Risk Assessment and Mapping of Conflicts of Interest - Risk Assessment Committee 3 Business Management 4 Custodian Agreements 5 Internal Controls 6 Third Party Vendor Contracts 1 March 2009
2 Sample Annual Activity ed Taken/ Code of Ethics 6 Personal Account Dealing 7 Inducements/Gifts/Entertainment 8 Outside Business Activity 9 Insider trading 10 Annual IAR Compliance Meeting Trading or Dealing Practices 11 Soft Dollar Commissions 12 Best Execution 13 Aggregation and Allocation s 14 IPO Allocation 15 Investment Guideline Compliance 16 Dealing Errors 2 March 2009
3 Sample Annual Activity ed Taken/ Marketing and Advertising 17 Marketing Suitability 18 Advertising Materials 19 Third-Party Solicitors 20 Brochure Rule 21 Performance-Based Fees Operations 22 Settlement Reconciliations 23 Performance Calculations 24 Billing Accuracy 25 Valuation and Reporting 26 Proxy Voting 27 Custody 28 Audit Offices of IARs - Annual Compliance Questionnaire 3 March 2009
4 Sample Annual Activity ed Taken/ Securities Filings 30 Form 13F Filing 31 Schedule 13G or 13D Filing Regulatory Filings 32 Form ADV I and II Updates - ADV Part I Annual Update - ADV Part II Offer 33 Notice Filings 34 Investment Adviser Rep. Filings (U-4's) - U-4 35 De Minimus and State Registrations 4 March 2009
5 Sample Annual Activity ed Taken/ Client Disclosure and Reporting 36 Privacy Policy - Annual Notice 37 Advisory and Sub-Advisory Agreements - Client Agreements - Annual Due Diligence on Sub- Advisors 38 Side Letters 39 Conflicts of Interest 40 Complaints 41 Update Customer Investment Objectives and Risk Tolerance 5 March 2009
6 Sample Annual Activity ed Taken/ Technology Controls 42 Retention 43 Disaster Recovery - Third Party Verification - Recovery Tests 44 Privacy Safeguarding - Monitoring of Third Party Vendors procedures - Testing of s The "Sample Annual Checklist" is provided by Integrity Compliance Consulting, Inc. It is not an exhaustive list of annual compliance reviews. Each investment adviser's business is unique and its annual review checklist should be tailored to that business. For a fully customized annual review checklist contact Dave Millar at or dmillar@integrity2c.com. 6 March 2009
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