Kyle Wiggs / Writing / Running the firm
Running the firm
Weekly tasks get done because you notice when they are missed. Annual ones get missed because nothing reminds you until it is late.
An annual review of the compliance programme. An annual updating amendment to Form ADV. Delivery of the brochure or a summary of changes to clients. Registration renewals. Code of ethics acknowledgements and personal trading reporting.
Specifics depend on your registration and structure. This is a shape, not a checklist — your compliance consultant supplies the actual one.
Nothing fails visibly if they slip. Weekly reconciliation gets done because the discrepancy grows until someone notices.
An annual review missed produces no signal at all until an examination.
Amending the ADV is remembered. Delivering the updated brochure to every existing client is frequently not, and it is a separate requirement.
Filing is the part firms remember. Delivering is the part they forget.
The annual compliance review is not complete when the thinking is done. It is complete when there is a dated document recording what was reviewed, what was found, and what was changed.
A review that happened without a record did not happen, for these purposes.
Not to the firm. A named individual, with dates in a calendar that generates reminders weeks ahead rather than on the day.
Done properly it is the one occasion each year the firm examines whether its stated processes match its actual ones.
The gap between those two is where nearly every finding comes from, and it is worth an afternoon regardless of the obligation.