Broker Dealers

Our firm is built on our broker-dealer expertise and that experience comes from establishing broker-dealers through New Membership Applications (“NMAs”) and also from running broker-dealer firms.

CPO & CTA

Traditional futures and commodities managers (including CTAs, CPOs, IBs and FCMs) understand the detailed, time-consuming, and sometimes frustrating process of establishing and maintaining a CFTC and NFA compliant firm.

Digital Assets

We believe that digital assets and new protocols are the future. For digital asset managers, we know compliance and we have a deep understanding of the specific issues that matter in this new space.

Fintech

The investment management industry is undergoing a sea-change led by fintech entrepreneurs. Innovation in how people consume financial information, save, invest, make loans, and make payments have made financial life easier and faster in many profound ways – however, the old way of financial regulation still applies to many fintech firms.

Investment Advisors

Traditional investment advisers and wealth managers have been the backbone of the investment management industry. As their businesses evolve to meet the demands of a changing demographic equipped with on demand technology, the ways of previously dealing with compliance change.

service offerings

The core of any successful business is a solid foundation of firm specific operational procedures and controls. Our team of experts are dedicated to breaking down complex situations and helping our clients understand how to effectively comply with applicable financial services regulations. Aspect Advisors provides highly customized and detailed compliance consulting services for the financial services industry to assist them in this endeavor. Clients can focus on their area of expertise and grow with confidence.

Full Service Offerings

CHIEF COMPLIANCE OFFICER & FINOP

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Outsourcing the role of Chief Compliance Officer benefits Investment Advisors by alleviating a variety of compliance related burden to us.

WE CAN PROVIDE THE FOLLOWING SERVICES, IN ADDITION TO BESPOKE ENGAGEMENTS:

  • Dedicated expert to serve as your CCO, including availability for use in marketing materials if desired.
  • Dedicated specific hours exclusively for your company
  • Sit on Risk and/or Investment Committee
  • Report to Management and/or Board of Directors
  • Policy development and implementation
  • Attend team meetings and/or presence on site
  • Due diligence on service providers/vendors
  • Maintain registration applications, as applicable (e.g. ADV, CRS)
  • Lead and conduct regulatory audits, including interview presence and drafting of all correspondence with regulators
  • Advertising Compliance
  • Conduct surveillance (email correspondence, investments/trading, gifts and entertainment, political contributions, outside business activities, and potential conflicts of interest, etc.)

COMPLIANCE PROGRAM & IMPLEMENTATION

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Aspect Advisors’ consultants will customize and maintain manuals, matrices, and employee training materials based on your operational requirements. As you add new staff or business lines, we will ensure that your procedures adapt with your growth.

SOME OF THE MOST COMMON EXAMPLES INCLUDE:

  • Policies and Procedures Manual / Written Supervisory Procedures (WSPs)
  • Code of Ethics
  • Risk Inventory and Assessment
  • Privacy Policy
  • Business Continuity / Disaster Recovery Plan
  • Cybersecurity Plan and Assessment
  • Anti-money laundering and USA Patriot Act Policies and Procedures
  • Internal Operational/Financial Controls

INDEPENDENT & HYBRID RIA

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Independent and Hybrid RIAs face unique compliance challenges. Technology and Custodial broker-dealer relationships drive many of the levers compliance systems are built on. Advisors are independent and expect the latitude to do the best for their Clients. Advisory practices are bought, sold, and merged frequently.

Aspect understands these challenges and brings a depth of expertise in this area and will apply best practices for compliance given the constraints within the space. We approach compliance with efficiency in mind. We know our client’s resources are limited, and we strive to find the solution that fits with the Firm’s risk appetite, in the easiest, most cost-effective way possible.

WE CAN PROVIDE THE FOLLOWING SERVICES, IN ADDITION TO BESPOKE ENGAGEMENTS:

  • Organization structure consulting, limited purpose broker dealer creation.
  • Annual Reviews – 206(4)-7
  • Full or Partial Mock Audits
  • Due Diligence for Practice Acquisitions
  • Supervisory Review
  • SEC Exam assistance
  • ADV Filing / Amendments
  • Program Creation or Review including:
    • Branch Audit Program
    • Review of new Business Lines
    • Account Surveillance
    • Onboarding / Advisor Review
    • Investment Committee Review
    • Advertising Policy / Review
    • New Account Procedures

SEC EXAM SUPPORT

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Regulatory examinations are inevitable and the examiners have increasingly sophisticated tools at their disposal. Our team takes audit preparedness seriously as we understand the impact that both the audit process and result can have on you from many different perspectives. To mitigate these potential issues, we implement systems of surveillance and periodic testing with the goal of identifying and reducing risk while minimizing the burden on your staff.

To ensure that your procedures are up to date on best practices and being implemented appropriately so that standards of conduct are not violated, Aspect will:

  • Assist with surveillance of employee activities related to investments/trading or private securities transactions (PSTs), gifts and entertainment, political contributions, outside business activities (OBAs), and other potential conflicts of interest.
  • Conduct an annual review of policies and procedures required by state rules, Rule 206(4)-7 of the Investment Advisers Act, FINRA Rule 3120/3130, or NFA Self-Examination.
  • At your discretion, we can conduct a mock regulatory examination, which is intended to mimic an audit that you would receive from your current regulator.

When the time comes for your examination our team will assist from start to finish, including interview preparation, on-site interview presence, and drafting of all correspondence with regulators. At this point you should feel confident that your books and records are in order, your procedures are sufficient and practical, and that there are no surprises waiting for you.

Back Of house Offerings

CHIEF FINANCIAL OFFICERS

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Independent and Hybrid RIAs face unique compliance challenges. Technology and Custodial broker-dealer relationships drive many of the levers compliance systems are built on. Advisors are independent and expect the latitude to do the best for their Clients. Advisory practices are bought, sold, and merged frequently.

Aspect understands these challenges and brings a depth of expertise in this area and will apply best practices for compliance given the constraints within the space. We approach compliance with efficiency in mind. We know our client’s resources are limited, and we strive to find the solution that fits with the Firm’s risk appetite, in the easiest, most cost-effective way possible.

WE CAN PROVIDE THE FOLLOWING SERVICES, IN ADDITION TO BESPOKE ENGAGEMENTS:

  • Organization structure consulting, limited purpose broker dealer creation.
  • Annual Reviews – 206(4)-7
  • Full or Partial Mock Audits
  • Due Diligence for Practice Acquisitions
  • Supervisory Review
  • SEC Exam assistance
  • ADV Filing / Amendments
  • Program Creation or Review including:
    • Branch Audit Program
    • Review of new Business Lines
    • Account Surveillance
    • Onboarding / Advisor Review
    • Investment Committee Review
    • Advertising Policy / Review
    • New Account Procedures

REGULATORY FILINGS

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Aspect Manages your Regulatory Status and your Regulatory Filings. You have enough on your plate driving revenue and performance and keeping your clients satisfied. Aspect Advisors can oversee preliminary and periodic requirements to initiate and maintain the regulatory status that fits your business needs.

FILING SERVICES INCLUDE

  • Draft, review and maintain applications for registration with individual states, SEC, FINRA, CFTC, NFA, and other pertinent regulators.
  • Complete all of the required paperwork and filings, and correspond with the applicable regulator(s) on your behalf during a registration or business expansion.
  • Monitor your asset levels, customers’ locations, and investing/trading activity to determine ongoing filing requirements in different jurisdictions and will make associated filings on your behalf.

REGISTERED INVESTMENT ADVISERS (RIAS) AND FUND MANAGERS

  • Form ADV
  • Schedule 13D/G, 13F, 13H
  • Form PF

COMMODITY TRADING ADVISORS (CTAS) AND COMMODITY POOL OPERATORS (CPOS)

  • Form 7-R
  • Annual Questionnaire and Annual Report
  • Form CPR/PQR

BROKER-DEALERS (BDS)

  • NMA, CMA, Form BD
  • Form U4, Form BR
  • Rule 2210, Rule 4530, and Rule 5123 Reporting

SCALE YOUR BUSINESS

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Aspect Supports Marketing, Business Development, and Expansion.

To effectively grow your business, you need confidence that your opportunity is communicated to the world in accordance with regulatory standards. We ensure that your target audience, preferred means of messaging, and marketing strategy are in line with the most recent regulatory rules, opinions, and expectations.


SERVICES INCLUDE:

  • Review all marketing, advertising, or communications materials including website, pitchbooks, tear sheets, blog posts, and other ideas you may have.
  • Assist with the launch of new products/business lines including associated regulatory filings, drafting/implementing new operational procedures, employee training, and customer notification or conversion.
  • Assist with reporting to third-parties such as your stakeholders (e.g. investors or board of directors)
  • Assist with investor/client due diligence and DDQs/RFPs, and coordinate with solicitors and/or placement agents.

Sometimes the most valuable service we provide is talking through scenarios with you to determine whether and how certain ideas of yours can come to fruition

BESPOKE PROJECTS

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Do you have a project that doesn’t quite fit into any of the categories above? Aspect Advisors can support project-based needs to help clients get from one stage to another.

Let us know what’s on your mind. We can help.