Written Policies, Procedures And Internal Controls

Are your policies and procedures up to date? Have you evaluated conflicts of interest to determine what policies and internal controls you may need? Have you evaluated the effectiveness of your protocols? Do your supervisory procedures articulate who is responsible for which areas and describe the supervisory process? How will your firm's suitability practices fare under the regulator's microscope?

Without legal counsel, answering these questions can become a daunting task.

Experienced Compliance Attorneys

At JLG, we help securities and financial services industry clients develop effective written policies, procedures and internal controls that help prevent abuses, detect and mitigate conflicts of interest, reduce firm risk and maintain compliance with firm protocols and regulatory requirements.

Our systematic approach helps to define the roles and responsibilities of the firm's senior management and area supervisors while promoting successful business practices for personnel to adhere to. To help accomplish this, ongoing counsel and support services offered by our firm and professional staff may include:

  • Creation, review or enhancement of written supervisory procedures (WSPs) or written policies and procedures manual
  • Development of GIPS® policies and procedures
  • Development of a code of conduct
  • Development or review of code of ethics, including personal trading processes, protocols to prevent misuse of material nonpublic information and protection of insider information
  • Gifts and entertainment reporting
  • Employee training on new policies and procedures
  • Development of business continuity and cybersecurity plan documents
  • Development of Anti-Money Laundering Programs
  • Assessment of portfolio management policies and procedures, including oversight of trading activities, soft dollar arrangements, best execution practices and review of best execution processes, directed brokerage protocols and compliance with SEC and FINRA recordkeeping requirements
  • Evaluation and implementation of recordkeeping and document retention policies
  • Review and assessment of privacy policies and procedures and safeguards for protecting confidential client information
  • Development, review and assessment of supervisory controls and protocols for communication with investors
  • Analysis of conflicts of interest processes
  • Annual testing of policies, procedures and internal controls, with written assessment upon request

Jacko Law Group (JLG) provides ongoing legal support services to help clients develop effective written policies, procedures and internal controls with a practical, systematic approach toward compliance.

For more information or to speak with a securities attorney — contact our San Diego law office directly at 619-298-2880 or contact us online.