Compliance

Conformity360 (“C360”) provides access to compliance consultants who are former regulators, Chief Compliance Officers and legal counsel, experienced in the financial services industry, as well as regulatory and technology experts who work with investment advisers, hedge funds, broker-dealers (dual registrants), and related entities to address applicable regulatory obligations, including the provision of support of registration, routine reviews and filings, technology, and other regulatory requirements.

C360 can assist with new and established firms with their regulatory compliance needs, regardless how small or large the firm is. C360 provides the following services as a package, or ala carte:


SEC Registration and FINRA Support


Registration

  • Advise on all aspects of, assist with, and file with the SEC:
    • New adviser registrations, from start to finish
    • Form ADV updates
    • State-to-SEC Transition Filing
  • Create and customize compliance manuals
  • Develop and implement anti-money laundering (AML) policies and procedures
Regulatory Support
  • Annual Amendment and Regulatory Filings
  • Annual Reviews – Rule 206(4)-7
  • Create and customize compliance manuals and code of ethics
  • Perform internal control reviews
  • Develop and implement anti-money laundering (AML) policies and procedures
  • Develop and provide policies for business continuity and cybersecurity plans
  • Conduct SEC mock examinations
  • Facilitate state registration
  • Prepare and conduct annual compliance meeting
  • Review of advertising and related marketing
  • Provide updates regarding changes in applicable SEC and NFA rules and regulations
  • Provide general regulatory inquiry assistance
  • Provide regular surveillance (e.g. personal trading, electronic communications)
  • Perform Best Execution, Soft Dollar, Trade Allocation and Proxy Voting Compliance Reviews
  • Perform Risk Assessment/Gap Analysis
  • Creation and updates of SEC Regulation Best Interest and Form CRS

NFA Registration and CPO/CTA Support


Registration
  • Advise on all aspects of CFTC registration and assist with filings with the NFA:
    • Assist with filing of CPO and CTA exemptions
  • Create and customize compliance manuals
  • Develop and implement anti-money laundering (AML) policies and procedures

Regulatory Support
  • Assist with Regulatory Filings
  • Annual Compliance Reviews
  • Create and customize compliance manuals and code of ethics
  • Perform internal control reviews
  • Develop and implement anti-money laundering (AML) policies and procedures
  • Develop and provide policies for business continuity and cybersecurity plans
  • Conduct NFA mock examinations
  • Prepare and conduct annual compliance meeting
  • Review of advertising and related marketing
  • Provide updates regarding changes in applicable CFTC and NFA rules and regulations
  • Provide general regulatory inquiry assistance
  • Provide regular surveillance (e.g., personal trading, electronic communications)

Broker Dealer


Registration

Initial FINRA New Member Application (NMA): C360 compiles, prepares and files all required documentation, including required documents such as Written Supervisory Procedures, Business Continuity Plans, etc. with FINRA and deal directly with FINRA staff on the firm’s behalf until the firm’s FINRA member is approved, as well as follow-up implementation services.

Continuing Membership Applications (CMA): C360 assists with changes in ownership, material business or operational changes, including additions of products or services lines, branches and representatives, which trigger a filing with FINRA.

Exchange and State Applications: Solid knowledge and experience in exchange and jurisdiction registration for firms and individuals includes the filing and monitoring of applications and acting as your representative for all related inquiries or issues.

Regulatory Filings: C360 prepareS Form BD, Form BR and other FINRA and SEC required filings as necessary.


Ongoing Compliance Support


C360’s ongoing broker-dealer and registered investment adviser compliance offering includes access to the staff for regulatory and compliance questions. These services can be customized to your needs and typically include:

  • Compliance Manual and Supervisory Procedures Updates
  • Automated Compliance Tools
  • Advice Concerning Changes in FINRA Rules and SEC Regulations
  • Assistance with Correspondence with the SEC, FINRA and other Relevant Regulatory Bodies
  • Ad-hoc Regulatory Advice
  • Activity Reviews
    • OSJ/Branch Reviews
    • Trading/Activity Reviews
    • Electronic Communication Reviews
  • Regulatory Reporting
    • Forms BD, U-4, U-5, ADV, etc. Amendments
    • CAT Reporting
    • Trade (ACT, TRACE, etc.) Reporting
  • Independent Consultant/Investigator
  • Electronic Trading Consulting
    • Cybersecurity Reviews
    • Direct Market Access (DMA) Assessments
    • Sponsored Access Testing
  • Continuing Education
    • Electronic Delivery of Relevant Training Modules
    • Compliance Training and Education

Annual Review Gap Analysis

C360 conducts annual internal compliance reviews of a firm’s compliance program as required by FINRA Rule 3010 and SEC Rule 206(4)-7, including a review of all business lines, operations and the firm’s written supervisory procedures to determine the firm’s level of compliance with applicable SEC and FINRA rules and regulations and the performance of the compliance staff in executing their required tasks.