Compliance Program Reviews, Mock Exams, and Gap Analysis

Identify gaps in your firm’s governance and control arrangements and policies and procedures.

Periodic testing of your firm’s governance and control arrangements, as well as its policies and procedures, is essential to help avoid the cost and reputational risk of future scrutiny and potential enforcement.

Whether you’re looking to fulfill your annual compliance program review as mandated by Rule 206(4)-7 of the Investment Advisers Act of 1940, your FINRA required annual review, or need to determine if your firm is acting within the remit if its FCA Part 4A license permission, we can help.

Our solutions

Our review services look under the hood of your compliance program to ensure the policies and procedures you’ve set are up to date and appropriate for your firm. We can provide Mock SEC, NFA, and TFCE Exams, as well as FCA Mock Audits, in-depth analysis of your firm’s GABRIEL returns, and your Internal Capital Adequacy Assessment Process (ICAAP).

Mock SEC Exams

ACA specializes in preparing both US and non-US-based advisers for SEC examinations through our mock SEC audits. Our team will conduct these inspections in very similar circumstances to an actual exam. Following an ACA mock exam, your firm will know what to expect and will be in a position to address any deficiencies.

Trading, Financial, and Compliance Examinations (TFCE)

Our team conducts comprehensive reviews of broker-dealer equity trading desks intended to emulate the TFCE performed by FINRA’s Market Regulation Department. We also offer more limited reviews for OATS, TRACE and RTRS compliance.

NFA Mock Exams

After completing our mock exam, your firm will: know how to prepare for its next NFA exam, be aware of potential deficiencies and corrective actions, and understand how your compliance program stacks up against your peers.

FCA Compliance Assurance Review

Provides you with a high-level and efficient means of determining whether your firm is acting within the remit of its Part 4A Permission license, that your compliance infrastructure is complete and accurate, that the appropriate controls are in place and that your regulatory filings are being made.

FCA Compliance Health Check

Provides a review of the same areas as a compliance assurance review, as well as a review of your compliance infrastructure. This includes benchmarking relative to industry best practices, regulatory themes and guidance; additional control environment testing; additional staff member interviews; and, cross-validation of submitted RegData returns.

In addition to ACA providing an exception-only report at the end of our review, your firm will receive a copy of the high-level assurance compliance monitoring programme undertaken.

FCA Mock Exam

Provides an assessment of all areas detailed within an FCA compliance health check, in addition to control environment interviews with non-compliance staff and general interviews with other staff members; a post-interview feedback session commenting on regulatory knowledge of individuals interviewed and your firm’s overall compliance culture; in-depth analysis of your firm’s GABRIEL returns and where relevant your Internal Capital Adequacy Assessment Process (ICAAP); and, a presentation to your firm’s senior management relative to ACA’s review findings.

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Why work with us?

Regulatory gaps, failings or weaknesses can result result in fines, reputational damage, and even criminal sanctions. In each ACA FCA mock exam and health check conducted, our team identifies 24 different regulatory exposure points on average.

Gain the peace of mind that comes from working with the most trusted and experienced GRC advisor in the financial services industry. With former SEC, FINRA, FCA, NFA, CFTC, OCC, and state regulators along with former along with former Chief Compliance Officers and senior compliance managers from prominent financial institutions, we offer a deep understanding of the regulatory landscape and the holistic use of technology to maximize efficiencies and provide true value.

Guide

Compliance Testing Action Plan

Investment advisers often have robust compliance testing programs in place to ensure their staff and control environment remain a well-oiled machine. Most of the time, such testing programs are front of mind and on top of the daily, weekly, or monthly to-do list. 

Yet over the past year – as compliance professionals have been forced to work from home during a global pandemic that comes with additional family obligations, enhanced day-to-day surveillance of staff, and adapting to changing expectations - testing has fallen to the bottom of the priority list. Unfortunately, the obligation to forensically test and/or stress test your compliance program remains. 

Download our Compliance Testing Action Plan to help you and your firm get started. 

Latest insights

New Public Disclosure Obligations Under the IFPR: What, When and How?

On 26 November 2021, the FCA published its third and final Policy Statement, PS21/17, on the new Investment Firm Prudential Regime (IFPR), which subsequently came into force on 1 January 2022. The new prudential rules introduce more complex and onerous disclosure requirements for affected firms. Here we examine what these new obligations mean for MIFIDPRU firms.

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SEC No-Action Letter Regarding Amended Rule 15c2-11

The SEC staff provided additional time for firms to comply with the amendments to Rule 15c2-11 in a no-action letter published in December, 2021.

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FCA Confirms Changes to MiFID II Rules on Research Plus an End to RTS 28 Reports on Best Execution

The FCA published Policy Statement PS 21/20 on Changes to UK MiFID’s conduct and organisational requirements on 30 November 2021, confirming the FCA’s proposals as set out in Consultation Paper CP 21/9.

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Q1 2022 Regulatory Reporting Deadlines

Regulatory filing submission deadlines for the SEC, CFTC/NFA, and FCA/ESMA occurring from January through March 2022.

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ACA's Top 10 Articles of 2021

As we reflect on the past year, we wanted to take a moment to look back at our most popular articles from 2021.

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ACA's Top 10 Webcasts of 2021

As 2021 winds down and we prepare for the new year, we thought we would take a moment to look back at our most popular webcast topics of 2021.

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News

ACA Group Named Accounting/Due Diligence Firm of the Year by M&A Advisor

ACA Group announced today that ACA Aponix® is the recipient of the Accounting/Due Diligence Firm of the Year in the 20th Annual M&A Advisor Awards. The M&A Advisor Awards are the benchmark for dealmaking excellence, recognizing the leading M&A Transactions, Restructurings, Deal Financings, Product/ Services, Firms, and Professionals.

ACA Group Selected as a RegTech100 Company for 2022

ACA is delighted to be counted among the 100 most innovative RegTech companies in the financial industry.

ACA Group Named Best Regulatory Consultancy - North America by RegTech Insight

ACA is honored to be voted Best Regulatory Consultancy - North America in the RegTech Insight Awards 2021 USA.

Upcoming events

Annual Compliance Training - 26 January 2022

The regulator is clear, you and your team must review your competence and training needs regularly. This course is designed specifically to assist all staff in meeting and staying up to date with their statutory and regulatory obligations.

Online Training

Client Money - 27 January 2022

Financial services providers that hold or control client money or assets must follow specific rules outlined in the Financial Conduct Authority’s (FCA) Clients Assets Sourcebook (CASS). This course is specifically designed to assist teams in dealing with client money audits and the client assets report, as well as helping them stay up to date with statutory and regulatory obligations in this complicated area.

Online Training

ACA Group and NSCP Cybersecurity Program Survey Results

We've again partnered with the National Society of Compliance Professionals (NSCP) to provide financial services firms with an opportunity to gain insight into cybersecurity compliance programs. Join us as we present the results of the survey.

Webcast