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. 

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