By: Stephen Newman
While no one likes to focus on them, compliance and ADV filings are mandatory for wealth, asset, and investment managers. The SEC has new filing requirements regarding separately managed accounts and has updated the Advisers Act. The new rules focus on gathering data and back-up information. Are you up-to-speed on what’s expected?
Here are the details:
Separately managed accounts or unified managed accounts (SMA/UMA)
There are more required disclosures for separately managed and unified managed accounts (SMA/UMA) in aggregate. The SEC says, “We believe that collecting additional information about separately managed accounts will enhance our staff’s ability to effectively carry out our risk-based examination program and other risk assessment and monitoring activities.”
If you currently use a system that relies on spreadsheets or similar methods to manage individual accounts, this task will be labor-intensive. Here’s the good news: SS&C can help you meet all compliance requirements. Our software, including our Global Wealth Platform (GWP), reports on all accounts, specific accounts, and custom composites.
Written information given to clients
Previously, if you showed performance to 10 or more people, it had to be preserved. Now, a single person is the threshold. According to the SEC, “The collection of information under rule 204-2 is necessary for the Commission staff to use in its examination and oversight program.”
This places a significant burden on the back office, which must now track what is given to each client. With GWP, every client report is logged and archived, which provides a compliance advantage and allows advisors to build reports on the fly. This not only provides flexibility, it also allows you and your advisers to be more current with your web reporting. It eases the burden on the back office and makes it easier to service existing clients.