Indy/RIA Policies & Procedures Manual
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In the process of moving from wire to RIA currently getting paperwork organized (ADV, etc.) and was wondering if anyone knows where a Policies & Procesures Manual template could be found. Yes I know the template route is not the best but I don't have a ton of start up capital and am trying to save money where I can (most prices for this that I've seen are $600-$1000 from an attorney). Already done the rest of the paperwork and this is the last thing I need to do before breaking away. And yes I have already roogled! Any help is much appreciated.
King
I would ahve gone to RIA in a Box, or similar outfit to get your ADV, ADV IIa&b, Policy&Procedures, Privacy Policy, Investment Advisor Contracts (Investement Policy Statement and Financial Planning Agreements), Code of Ethics, FINRA Entitlement, and U4 filing for IAR. In addition, they dealt with all the follow-up questions from the State.
I was debating doing it on my own and I am glad I didn't.
I'm also looking for a compliance manual... for CA. -
You might try http://www.fpanet.org/professionals/FPAStore/ which has a 2009 compliance template for under $100. I've read somewhere that those templates don't cut it in CA, but haven't found an affordable option yet... so if you find anything else out, please do share the info.
I just had a mock audit done by my new dedicated comliance officer. The biggest deficiency he found was our template based P&P manual. I know that no one like spending money on this type of stuff, but the risk is you either pay now or pay later. If the state (CA for you) or SEC finds a make shift manual you're likely looking at a fine of $500 or more. Or, you could just pay $1,000 or so for a fully customized manual for your firm. Mine was a little unusual due to the nature of my business, but it ran almost $2,500 (SEC advisor primarily doing business in Michigan and California).
Since you're in CA I would suggest getting in touch with Jeff Groves of Compliance Works. He's in Redondo Beach and may be a decently priced option for you.
Hope this helps.
I agree with the earlier postings about RIA in a BOX. Other firms existing which are also quite good including AdvisorAssist, Dickinson Regulatory Alliance, MarketCounsel, etc., etc., The posting about the FPA template is correct, it is geared more for SEC registered firms but can be a great starting point for the State. Some states, based on what others have told me, are quite good in helping share their knowledge with new RIAs. I've heard great things about Ohio and California in this regard.
You also might want to visit The Consortium for templates, etc. at:
http://www.liftburden.com/online-store.html
Best wishes to you and your new RIA firm. It is an exciting model to choose and one that I'm sure will provide great personal and professional satisfaction.
Happy Holidays to you and your family!
Fred