For those firms with a fiscal-year end of December 31st, it is time once again to commence your Annual Amendments to Forms ADV.
It is imperative to assess what changes have occurred within your business, especially as they relate to products, services and fees assessed by the firm to your clients so that appropriate disclosures can be made within your Form ADV brochures.
Due to the heightened regulatory scrutiny on client disclosures, having your Form ADV created, evaluated and/or updated by the JLG Team could be essential.
Some of these essential items include:
- Advisory Fees and Expenses
- Best execution and use of soft dollars
- Code of Ethics policy
- Compensation arrangements
- Conflicts of interest
- Custodial arrangements
- Loans to principals / firm
- Material disciplinary events
- Outside business activities
- Discretionary authority
- Products and services offered – and how they may differ client to client
- Proxy Voting
- Trade aggregation, allocation and rotation policies
- Use of solicitors; and more