Code of ethics software for RIAs
The filings your code requires, in one place, with a decision on each.
Access persons file gifts, entertainment, political contributions and outside business activities themselves. You review, decide and move on. Everything is attributed and timestamped, because the record is the point.
Included in Solo, Firm and Firm Plus
A screenshot of the product, with a demonstration firm’s data.
The code of ethics rule requires a written code, a duty on access persons to report their personal securities holdings and transactions, and prompt reporting of any violation of the code to the chief compliance officer. The rule does not tell you how to collect any of it, which is why most firms end up with a spreadsheet and a folder of emails.
What it does
Employees file their own
An access person sees their own filings, not their colleagues'. They submit a gift or an outside activity in the product rather than emailing you a description you then have to transcribe.
Each filing on its own form
Gifts and entertainment, political contributions and outside business activities each have their own fields, and each waits for your approval or denial. Political contributions are checked against the pay-to-play de minimis amounts. Conflicts are recorded by compliance and tracked to resolution.
Breaches, tracked to closure
A breach is a record with a severity, the person involved and a state, and it keeps who resolved it and when. It stays open on the dashboard until it is resolved, which is harder to lose than a note in a file.
Attestations and certifications
Assign an attestation to named people, a group or everyone, with a due date, and watch who has completed it. Each person is told when it is assigned, and overdue ones are counted on the dashboard, so late is visible rather than discovered at the annual review.
Gift limits, measured for you
Set your firm's gift and entertainment limits. Each gift is measured against the year's running total with that person or company, and entertainment against the limit per event. Over the limit is marked; a person still decides.
Nobody approves their own
A filing cannot be approved by the person who filed it while someone else can approve it. A firm's only compliance person may, and the record says it was self-approved.
On Firm Plus, it feeds the risk score
On Firm Plus, how many gifts a person files and what they add up to, ongoing outside activities, open conflicts and breaches all feed each employee's daily risk score, and you are alerted when one turns high, so a pattern shows up before it becomes a finding.
Decisions are attributable
Every approval and denial carries who decided it and when, and a denial carries the reason given. That is what an examiner asks for when they ask how a gift was handled.