Comprehensive Compliance Law P.C.

Compliance Consulting with Purpose

We go to bat for your firm, optimizing and improving every facet of your firm’s compliance program, down to the last detail. Our extensive experience combined with our strong work ethic and attention to detail produces superior outcomes.

• We guide you through designing, implementing, reviewing and updating your firm’s compliance protocols on an ongoing basis.
• We conduct monthly compliance calls.
• We provide ongoing compliance testing.
• We file all required regulatory filings and provide documentation in the form of compliance memorandum to include in the compliance folder.
• When the SEC examiners eventually arrive, our goal is to have equipped you with the documents, tools and professional guidance for your exam to run smoothly. We are with you to manage every aspect of the exam process.

Our services are customized to meet the specific needs of each client. We work collaboratively throughout the entire process and guarantee measurable results. Contact us to find out how we can help today.

SEC Examination Support

We find that our SEC Examination Support is a very highly valued service by our clients. Clients are very thankful and appreciative after an examination is complete. Our collaborative effort with clients includes our taking the lead on the examination. We prepare the firm’s staff for the SEC interviews. We manage the exam process and SEC document requests. Our focus is a quick examination that minimizes the disruption of your business. We work to ensure that all required documents are provided in a clear understandable fashion and that all follow-up questions are answered appropriately. We prepare responses, manage the exam exit and any required or requested improvements.

Annual Reviews

• Annual compliance reviews are performed, as required by Rule 206(4)-7 of the Advisers Act, to assess the adequacy and effective implementation of the written policies and procedures designed to prevent violations of the Advisers Act, applicable securities laws and regulations by the firm and its personnel.
• A large array of the required books, records and other documents are gathered and analyzed to determine any omissions, weaknesses, deficiencies or violations.
• Changes to the business are also reviewed to ensure adequate coverage from the existing policies and procedures.
• Updates and changes to existing legal and regulatory requirements are reviewed and compared to the firm’s existing policies and procedures.
• Each component of the entire compliance program is reviewed individually, and appropriate update recommendations are made.
• An extensive annual review memorandum is then drafted and any recommended changes are added to our action list. The policies and procedures are then updated accordingly.

Compliance Policies and Procedures, Manuals and Code of Ethics

It’s a daunting task trying to remain compliant with a myriad of SEC rules and regulations. We design a program to tackle compliance that is both manageable and practical. We keep the compliance burden reasonable by not creating unnecessary policies or procedures and by carefully tailoring the compliance program to your individual firm.

• As the architect of your compliance program, we create, develop, review, and draft your compliance policies and procedures including your compliance manual and code of ethics.
• We review and update your compliance manual on an annual basis or as required to reflect changes in your firm’s business or the regulatory environment.

Compliance Risk Analysis

• We determine the compliance risks relevant to your firm.
• We use this analysis to build a risk inventory system that includes specific areas tailored to your firm’s unique lines of business.
• After this risk assessment matrix is created, we update it annually and use it as a basis to evaluate and further develop your overall compliance program.

Compliance Calendar

• We draft a Compliance Calendar specific to your firm, which outlines all required compliance tasks. It is updated annually or more frequently if necessary.
• We execute the tasks created on the calendar so you and your team are free to focus on building your business.

Electronic Communication Reviews

• Email, social media and text communications are reviewed as required utilizing key words customized for each client.
• These key words relate to the client’s current business offering, issues uncovered during compliance and other reviews, and SEC hot button topics.
• Additional search words harvested from other sources are also used when appropriate.
• We then turn our attention to random email samples and review them more thoroughly to identify activity that does not conform with compliance policies and procedures, or federal securities laws.
• This process also helps us identify any changes in operations, activities, or practices that require updates to your compliance policies or amendments to SEC Form ADV.
• Reviews are conducted either monthly or quarterly and are formally recorded in a memorandum which includes the review statistics, sample email findings, our observations and our recommendations.

Compliance Testing

We perform a wide variety of compliance testing on a monthly or quarterly basis to assess the effectiveness of your compliance program and avoid violations of the Advisers Act, securities laws and regulations. Assessment areas include:

• Marketing and Advertising Reviews
• Investment Mandate Compliance testing
• Political Contributions Testing
• Outside Business Activity Oversight
• Trade Blotter Surveillance Reviews
• Third Party Service Providers
• Code of Ethics Policy Reviews
• Employee Trading Reviews
• Best Execution Reviews
• Business Continuity Plans
• Cybersecurity Testing
• Financial Condition Reviews
• Contracts

SEC Mock Exams

We conduct mock SEC exams to assess your firm’s readiness for SEC examinations. We provide document request lists, review documents, conduct interviews and determine areas for improvement.

Compliance Training

We provide a full range of firm-wide and CCO compliance training.

• While conducting compliance training, we also prepare and distribute compliance training materials, including presentations.
• Part of this process includes a review of your firm’s legacy training materials.
• Training materials can either be distributed, or training sessions can be conducted on-site or remotely.

Regulatory Filings

We prepare and file all required regulatory filings and/or assist with filings. Filings include ADV filings (preparation of ADV Part 1A, 2A, 2B and Form CRS), Form PF filings, Form D, Form 13 filings, etc.