Investment Adviser Compliance Programs

Registered investment advisers must adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Investment Advisers Act. Each adviser must designate a chief compliance officer responsible for administering the policies and procedures.

The compliance program must address portfolio management processes, trading practices, accuracy of disclosures, safeguarding of client assets, record keeping, marketing, and valuation methodologies. Advisers must review the adequacy of their compliance policies at least annually.