Once a registered investment adviser has developed written supervisory and compliance policies and procedures, what happens?
The first step that should be taken after developing written supervisory and compliance policies and procedures is to provide all employees of the investment adviser with a copy or access to a copy. The investment adviser should require all investment adviser representatives (“IAR”) and employees to review the supervisory and compliance policies and procedures and have each investment adviser representative and employee sign an acknowledgement indicating that he or she has read this compliance manual, understands it and agrees to abide by the investment adviser’s written supervisory and compliance policies and procedures. (Although a signed acknowledgement is not a requirement, it is a good business practice.) A registered investment adviser should provide its investment adviser representatives and employees with on-going training of its supervisory and compliance policies and procedures. An investment adviser must also notify investment adviser representatives and employees when revis
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