Compliance Program Reviews, Mock Exams, and Gap Analysis

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

Whether you’re looking to fulfill your annual SEC compliance program review as mandated by Rule 206(4)-7 of the Investment Advisers Act of 1940, your FINRA required annual review, need to conduct a gap analysis to determine if your firm is acting within the remit of its FCA Part 4A license permission, or want some assistance with thematic reviews or consistent regulatory consulting throughout the year, we can help. 

Conducting 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.

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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 RegData returns, and your Internal Capital Adequacy Risk Assessment (ICARA). 

Mock SEC Exams

ACA specializes in preparing both U.S. and non-U.S.-based SEC registered advisers for SEC examinations through our mock SEC exams. Our team will conduct these Registered Investment Advisor (RIA) mock exams in very similar circumstances to an actual SEC exam. By performing a mock exam with us, we will help you to understand what to expect during an SEC examination as well as identify any deficiencies in your compliance program, policies, and procedures in line with Rule 206(4)-7.  

Trading Reviews

Our team conducts comprehensive reviews of broker-dealer equity and fixed income trading desks intended to emulate the trading reviews performed by FINRA’s Market Regulation Department. The trading reviews cover Municipal Real Time Reporting System (RTRS), Trade Reporting and Compliance Engine (TRACE), and The Consolidated Audit Trail (CAT).

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. We shall also review your policies and procedures for appropriate rule referencing and completeness. 

FCA Compliance Health Check

Provides a review of the same areas as a compliance assurance review, as well as a detailed 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. At the end of the review, you will receive an exceptions-based report. 

FCA Mock Audit/ Exam

Provides an assessment of all areas detailed within an FCA compliance health check, but a mock audit (sometimes referred to as a mock-exam) has the added benefits of 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 RegData returns and where relevant your Internal Capital Adequacy Risk Assessment (ICARA); 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 in fines, reputational damage, and even criminal sanctions.  

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. 

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