Compliance Program Reviews, Mock Exams, and Gap Analysis

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.  

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).

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. 

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. 

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. 

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.