Access to Broker Dealer and RIA Compliance Firms to Assist with SEC, FINRA and DOL Regulations

To continue to add more value and assist our advisor partners, APG has under- taken a holistic approach to practice and risk management. This means assisting our advisor partners respective RIA and broker dealer firms as well. This macro perspec- tive is necessary given the continuing and massive levels of SEC, FINRA and DOL regulations and enforcement. This reality has placed a greater emphasis on risk management. This means the governance models must have greater checks and balances, procedural documentation and significant training enhancements both on a firm level and advisor level. For example, there has been a proliferation of Registered Investment Advisory firms. This growth trajectory must have a paral- lel governance model to ensure SEC and FINRA compliance. Developing proper procedures, regulatory reviews, and mock audits help to ensure compliance and avoid costly fines and penalties. Significant and ongoing training on a supervisory level is necessary given the ever changing regulations. Specific training modules must be customized to each firm, implemented and monitored. Understanding the DOL service provider disclosure regulations has transcended from the advisor level to the practice level. This now requires new thought processes encompassing more rigorous compliance models. Through the purview of the service provider rules, the DOL has expanded its audit scope to RIAs and broker dealers. Targeted areas of revenue sharing, non-level compensation, prohibited transactions and fiduciary status, have left an uneasy status and often confusing action plan for RIAs and broker dealers.

Fortunately, APG through the ARCC network has secured access to national compliance expertise for RIA and broker dealer firms covering all three strategic areas of SEC, FINRA and DOL compliance. These key services through ARCC affili- ated organizations include due diligence compliance assessments, customized risk management programs, procedural maintenance programs, and necessary ongoing filings. This clarifies what the compliance traps are, defines what is needed, and puts forth a strategic action plan. Of course, continuing our ARCC mission of add- ing value, the fee schedules for these critical services have been duly negotiated for the benefit of our advisor partners and their respective firms.