Policies and Procedures Manual
Why is this manual important?
The Utah Division of Securities, as authorized by Utah Code Ann. §61-1-5, may conduct an examination of certain books and records of which are required to be kept under Division Rule R164-5. Utah Code Ann. §61-1-5 (5) provides that these records “are subject at any time or from time to time to reasonable periodic, special, or other examinations by representatives of the Division, within or without this state, as the Division deems necessary or appropriate in the public interest or for the protection of investors.”
Who is required to have a Policy & Procedures Manual?
All RIAs are required to have a policies and procedures manual.
Best Practices
- Review Policies and Procedures Manual at least annually with all employees
- Keep a log of meeting attendance; attendees review manual and sign a “receipt of policies” form
- Include an annual ADV update checklist and a code of ethics in the manual; have each employee sign it
Creating a culture of compliance includes:
- A strategic vision
- Identification of specifics risks
- Control points for each of the risks
- Good documentation & accountability
What we are looking for:
Hiring/Training Processes
Handling Customer Funds/Custody
Protection/ Confidentiality
Employee Transaction Review
Correspondence Review
Advertising Review
Complaint Review
Solicitor
Outside Business Activities
Business Continuity/ Disaster Recovery Planning
Branch/Remote Office Supervision
Information has been provided by NASAA. You will be subject to all relevant laws, regulations, rules, and orders whether or not they are included in this information sheet.
