One perk of being a smaller investment firm is not having to stress over the supervision of multiple registered investment adviser representatives (IARs). However, with growth comes increased responsibility, especially when you get to the point of bringing on additional IARs. Like many industries, adding new people to the company brings on multiple challenges, and for Advisors, supervision needs to take priority.
With Growth, Comes Compliance
Many advisers that grow significantly over a relatively short time frame often find the transition difficult. Unfortunately, compliance is an area that has a tendency to fall by the wayside during rapid growth. Once an Adviser grows to the point where they feel it necessary to bring on one or more IARs, they should prioritize the assignment of a qualified individual to be the Chief Compliance Officer (CCO).
Upon the assignment of the CCO, there should immediately be an amendment to the Adviser’s written supervisory procedures to name the CCO and address how the CCO will supervise the IARs. Additionally, those amended procedures should be distributed to all IARs, and documentation maintained providing evidence they received and read the procedures.
With Compliance, Comes Regulators
One area in which regulators tend to focus on during an audit is the supervision of an IAR and their management of client accounts. That understood, it is vital for the Adviser to ensure written procedures are followed regarding:
- The opening of new accounts
- The collection and maintenance of the client suitability and risk information
- The continuous and ongoing review of an IAR’s management of client accounts
- The Adviser’s disciplinary policies when an IAR is not in compliance
Regardless of qualifications and perceived competence of IARs, the Adviser and named CCO are required to monitor their activities. The CCO is obligated by statute and the Adviser by fiduciary duty to clients; both which should reflect in the Adviser’s written policies and procedures.