Annual Reviews for State Registered RIAs
Investment advisers should review, no less frequently than annually, the adequacy of its written compliance policies and procedures and the effectiveness of their implementation. The states expect annual reviews to take into consideration any compliance matters that arose during the previous year, any changes in the business activities of the adviser or its affiliates, and any changes in the Investment Advisers Act or related rules that may impact the adviser’s policies and procedures. In addition, the state expects that an investment adviser will review its compliance policies and procedures on an interim basis in response to significant compliance issues, changes in business activities, and new regulation. In accordance with state rules, this memorandum summarizes the key components of annual reviews for the adviser.