NRS consulting services

Annual Compliance Program Review

Annual Reviews (206 (4)-7, 38a-1)

Risk Assessment

Due Diligence Review

Anti-Money Laundering Audit (FINRA Rule 3310)

CEO Certification Review (FINRA Rule 3130)

Supervisory Controls Review (FINRA Rule 3120)

Advertising Review

Compliance Department Organization Review

Record-keeping Review

Compliance Technology Review

Mock SEC Exam

Cyber Security Review

IA “Fiduciary Duty” Interpretive Release Check-up

“Regulation Best Interest” Targeted Onsite Compliance Review

“Soley Incidental” Interpretive Release Focused Offsite Review

Form CRS Preparation Consulting

On-site and remote reviews include:

• Compliance program review.
• Annual review.
• Mock SEC exam.
• Independent compliance consultant review.
• Anti-money laundering audit.
• Cybersecurity review.

As leading industry experts, NRS compliance professionals have helped hundreds of firms like yours tackle registration challenges to successfully register with state and federal regulators. NRS makes the process efficient and ensures that critical compliance controls are in place before your first regulatory examination.

NRS registration services also include a subscription to NRS ComplianceGuardian™ that provides many of the documents and tools your firm needs to design, implement and maintain your compliance program.

NRS provides registration services for:

• Investment Advisers.
• Broker-Dealers.

Registering as an Investment Adviser with the SEC or state regulators is increasingly complex. Completing the required registration documents requires time and expertise — whether you are a sole proprietor opening your own firm or a billion dollar private fund that is no longer considered exempt.

There is no reason to do it alone. NRS compliance professionals guide investment advisers through registration as you take the steps required to establish your practice. Rely on NRS for:

• Direct guidance and assistance in drafting your firm’s Form ADV documents, and SEC and state documents as required,
• Development of the firm’s policies and procedures customized for your compliance program, and
• Access to NRS ComplianceGuardian™, NRS’ trusted compliance platform that provides the documents and ongoing policy support required to design, implement and maintain your compliance program.

Open your new broker dealer firm with an effective compliance infrastructure from day one. Financial Industry Regulatory Authority (FINRA) membership does not come easily, especially considering the in-depth knowledge and exhaustive effort that is required to complete the appropriate filings.

NRS compliance professionals apply efficiency and knowledge to the process, guiding broker dealers through registration and helping you establish your practice. Rely on NRS for:

• Proper fulfillment of all compliance requirements, taking an in-depth approach to keep the process moving with minimal delays,
• Information and document organization on a firm’s behalf and with their collaboration, including the business plan, policies and procedures, education analysis and training plan, and all applicable FINRA forms (BD, U4 and BR),
• A liaison who will work with the firm and the FINRA examiner to review the application and respond to requests for additional information and documentation, and
• Access to NRS ComplianceGuardian™ that provides broker dealers with the tools required to design, implement and maintain an ongoing compliance program.

As part of the Investment Advisers Act of 1940 Rule 206 (4) – 7 (17 CFR 275.206(4)-7), investment advisers and dually registered firms are required to conduct annual reviews of their policies and procedures to assess their adequacy and effectiveness. In a 2017 Risk Alert, SEC staff noted that failure to conduct annual reviews, as required, or to address the adequacy of policies and procedures as a part of such reviews, were among the most frequently cited compliance issues cited in examinations. Non-compliance can result in firms incurring fines and penalties.

NRS consultant compliance professionals can help firms meet this annual requirement. NRS expert compliance professionals work with you, facilitating on-site reviews of  applicable rules and regulations to assess compliance, allowing you to meet the annual review requirement and to determine the effectiveness of your firm’s compliance program.

New ways to launder money and engage in fraudulent activities have put broker dealers under increased pressure to remain compliant. The USA Patriot Act and FINRA Rule 3310, require broker dealers and dually-registered firms to design and implement an AML program that includes appropriate policies and procedures, a customer identification program, and an annual review of the firm’s policies and procedures.

NRS audits a firm’s AML program to determine if it is compliant with FINRA rules and the USA Patriot Act. Working with key stakeholders at your firm, NRS expert compliance professionals conduct an onsite review and test of your firm’s AML program and related policies and procedures. NRS delivers a report addressing firm’s program soundness. This allows broker dealers and dually-registered firms to meet annual requirements as outlined by FINRA for an independent AML program review.

NRS expert compliance professionals:

• Review and test the AML written supervisory policies and procedures.
• Review client files with an emphasis on foreign clients.
• Review and test internal surveillance practices.
• Review the AML training plan for all appropriate personnel.
• Review for required AML documentation.
• Deliver a written report highlighting deficiencies and recommending appropriate corrective measures.

NRS Compliance Reviews help firms stay ahead of ever-changing FINRA, SEC and State Regulations. Our expert consultant compliance professionals execute a comprehensive assessment of your firm’s compliance program, test it against applicable regulatory requirements and expectations, and help identify and remediate compliance risks.

NRS conducts a thorough review with an emphasis on policies and procedures, regulatory requirements, and industry best practices to prepare firms for a regulatory examination, and to identify compliance risks. Reviews are tailored to fit your needs and include:

• Anti-Money Laundering Audit.
• Risk Assessment.
• Due Diligence Review.
• Cybersecurity Review.

NRS consultant compliance professionals have decades of expertise working in the private sector and for regulatory bodies. They bring unmatched expertise when reviewing your firm’s compliance procedures while navigating regulatory requirements and considering real-world business needs.

The SEC continues to emphasize that cyber security protection is critical to the operations of financial markets. In its recently released National Exam Program Examination Priorities, the Office of Compliance Inspections and Examinations (OCIE) reiterated that the Commission is focused on working with firms to identify and manage cyber security preparedness in the securities industry. NRS Cyber Security Review and our cyber security compliance professionals are here to support your efforts to remain in compliance in this challenging domain.

From emerging cyber-threats, to State and Federal mandates, CCOs must focus their time on marrying the right policies and procedures with the right technology solutions to secure the firm’s perimeter and mitigate risks. OCIE’s examinations focus, in part, on identification of risks and cyber security governance, protection of firm networks and information, risks associated with remote customer access, risks associated with vendors and third parties and detection of unauthorized activity.

Relying on the experience gained from providing custom compliance and technology services and solutions to the financial services industry, NRS offers a ‘right-sized’ approach that helps firms identify their cyber security risks: from closing the gaps that exist in a firm’s IT security infrastructure, to developing in-depth and customized cyber security policies with a focus on compliance.

NRS can deliver custom programs that help firms:

• Assess Cyber security risks.
• Develop the right policies and procedures.
• Train staff to think compliance first.
• Support the business through annual updates, reviews and strategic planning.
• Test vulnerabilities and application security.
• Manage the security risks with vendors and conduct the necessary due diligence.

Regulators and firms involved in enforcement proceedings often rely on NRS to serve as the independent compliance consultant approved to assist with oversight and remediation.

While the specifics vary based on the client’s situation, such engagements frequently include:

• Off-Site Review: NRS will request a series of compliance documents responsive to the issue outlined in the enforcement order or settlement agreement,
• On-Site Examinations: NRS will visit the firm’s office and conduct an examination through a series of exercises and interviews of the firm’s senior staff and personnel to review issues outlined in the enforcement order or settlement agreement,
• Off-Site Exam Report: Upon completion of its review, NRS will submit a report to the regulator outlining the review conducted, methodology, findings, and recommendations, and
• Other Services: based on the firm’s needs and the requirements specified in the enforcement order or settlement agreement.

The Securities and Exchange Commission continues to increase its exam pace especially for those investment advisers that have not been examined within the last three years. Through our Mock SEC Examination, NRS tests your firm’s preparedness for examination. The mock examination evaluates the ability and preparedness of your firm’s key personnel, processes and records to help determine if your firm’s commitment to compliance will meet regulatory expectations.

The NRS Mock Examination is executed in three stages:

Off-Site Review: As the SEC would do, NRS expert compliance professionals request a series of compliance documents to understand the firm’s unique business practices and then use those documents to prepare for an onsite examination.

Onsite Mock SEC Exam: NRS compliance professionals visit your firm’s offices and conduct a live mock SEC Exam through a series of exercises and interviews of the firm’s senior staff and personnel. Our compliance professionals hold a wrap-up meeting and deliver feedback. Topics covered during the mock session will include Risk Management, Trading Practices, Vendor Due Diligence, Form ADV Disclosure, AML procedures and others.

Off-site Exam Report: Upon completion of the onsite review, NRS will provide a written summary of the findings and any recommendations for corrective actions, which may include follow-up training for specific individuals or the firm as a whole.

Partner with NRS and our compliance professionals to ensure the timely and accurate filing of your Form ADV annual updating amendment and payment of annual renewal fees for your firm.

The Annual Updating Amendment Service provides support at two critical times during the year and includes:

Assistance with the annual IARD renewal of state registrations or notice filings for your firm and its investment adviser representatives during the IARD Renewal Program from November-January.

Assistance with filing the annual updating amendment to Form ADV within 90 days after your fiscal year end.

Gain compliance confidence – make NRS your compliance partner through the NRS Partnership Program. The program combines access to our expert compliance professionals, our education programs and courses as well as ComplianceGuardian™, our flagship software.

Your firm will benefit from a dedicated expert compliance professional and a full complement of consulting services as well as access to training and an annual subscription to ComplianceGuardian™. The NRS Partnership program is perfect for firms without a fully-staffed compliance department. Available in three configurations and varied price points, there is an NRS Partnership program that is right for your firm.

The NRS Partnership program includes access to our technology products, education solutions and a dedicated NRS consultant.

View our partnership packages.

Compliance requires a sophisticated mix of skills, responsibilities, knowledge and personal skills not readily available in many firms, that strain resources and threaten their ability to maintain compliance.

NRS Premier Compliance Partnership services are delivered by NRS’ expert compliance professionals and;

Supplement your internal compliance teams with deep expertise that helps your firm keep pace with changing regulations, and frees up valuable, internal resources to focus on specific compliance concerns and core business activities.

Services are:

• Flexible – outsource all or some of your compliance program components,
• Custom – offerings are individually designed to meet specific firm needs,
• Expert – highly skilled compliance professionals with extensive consulting engagement experience, and
• Continual – regular, offsite compliance testing and reporting in critical risk areas.

Put the renowned expertise of NRS compliance professionals in your corner with an NRS Premier Compliance Partnership. The program bundles several products and services that, in our decades of experience, have proven most advantageous to NRS clients including

• Risk Assessment & Gap Analysis
• Preparation of a Tailored Compliance Calendar & Testing Matrix
• Regular Offsite Compliance Testing and Results Reporting
• Form ADV Annual Updating & Other-Than-Annual Updating Amendments
• Dedicated Compliance Support
• Compliance Education
• Access to the NRS ComplianceGuardian™ Platform
• Annual Reviews
• Regulatory Examination Support Services

Typical Tasks include:

• Monthly Email Reviews
• Marketing Review
• Quarterly Trade Blotter Reviews and Best Execution Testing
• Semi-Annual Testing of Political Contributions
• State Notice Filing/Registration
• Investment Adviser Representative Licensure Verification