Compliance policy templates for investment advisers

The policy the rest of your program hangs from: who the chief compliance officer is, what authority they have, how the annual review works, and what happens when something goes wrong.

Standards of conduct, personal trading and reporting, pre-clearance, inside information, gifts and entertainment, political contributions and outside business activities, fitted to how your firm actually works.

Which records the firm keeps, where, and for how long, including electronic communications and the records other rules add.

What counts as an advertisement, how performance may be shown, when testimonials and endorsements are allowed, and how material is reviewed and approved before it goes out.

Safeguarding customer information, the incident response program and customer notification the 2024 amendments require, service provider oversight, disposal, privacy notices and identity theft red flags.

Which functions are critical and how fast each must come back, how a disruption is classified and the plan activated, who backs up whom, and how the plan is tested.

When the firm has custody, how client assets are held, how pooled vehicles meet the rule through audits, what to do with assets received by mistake, and how digital assets are handled.

Who values the portfolio and how, which methods and sources are used, how often, how overrides and challenges are handled, and how values flow into fees and investor reporting.

How brokers are chosen and reviewed, how orders are placed and aggregated, how research and soft dollars are handled, and what happens when a trade goes wrong.

How investment opportunities are divided among funds and accounts, who gets co-investment and on what basis, and how exceptions are approved and recorded.

When the firm may trade with a client for its own account, act for both sides of a trade, or move an asset between clients, and the disclosure, consent and approval each needs.

Every filing the firm may owe, when each is due, and who owns it, from Form ADV to beneficial ownership, Form PF, Form D and state notice filings.

Whether and how the firm votes for clients, the standard it votes to, how conflicts are handled, how proxy advisers are overseen, and what it discloses and keeps.

Sanctions screening, investor identification and due diligence, red flags and suspicious activity, and a plan for FinCEN's anti-money laundering rule for advisers.

What counts as a complaint, how staff report one, how it is investigated and answered, who can approve a settlement, and what is kept.

How the firm rates its vendors by risk, what due diligence each tier gets, what contracts must say, how service providers are monitored, and how the firm exits a relationship.

How the firm captures business email, how long it is kept and under what protection, who reviews it and how messages are chosen for review, how privileged mail is handled, and how employees are told.