PCA’s FOCUS Program Focused Ongoing Compliance Updates and Support PCA is pleased to offer a new program! We have found that many advisers struggle with managing the compliance function of their firm. Two significant areas of difficulty involve staff training and also knowing when to seek help in updating the compliance manual. The majority of firms simply do not have formal, documented compliance training. CCOs regularly tell us that they just don’t know where to start on a training program. Firms also struggle with keeping their written policies and procedures up to date. We are here to help, but until now our clients have had to bear the burden of thinking about when to call us to process an update to the compliance manual. As a result, we frequently find that when an adviser receives a notice of a regulatory examination, the compliance manual is woefully out of date. We want to help you focus your energy most effectively. In this Program, we will pre‐schedule an update of your compliance manual every 24 months. In addition, if there are new rules or other regulatory actions requiring changes to your procedures, we will automatically update your compliance manual for you. If you notify us of changes in your organization, we will also process those updates. When you sign up for this service, we will schedule an initial review of your manual. Once we have evaluated the current status, we will notify you as to whether your compliance manual needs an update right away or if it makes sense to schedule it in 2015 (or later if you have recently had an update). This will depend upon the date of the most recent update. Generally speaking, an overall review every two years should be sufficient, along with any interim updates required by changes in the rules or in your business operations. BENEFITS AND SERVICES (1) Each quarter we will provide an agenda and presentation materials for ongoing staff compliance meetings. The agenda items will be based on our Calendar of Review, which most of our clients use as the basis for planning their annual review of the compliance program. We will provide the materials to you in the ‘middle month’ of each quarter, which should give you time to work on reviewing the relevant parts of your compliance program before your training meeting by the end of the quarter. You can then use the materials we provide to conduct your training. (2) We will automatically update your compliance manual (and all exhibits, as applicable) every 24 months AND in response to regulatory changes. Each participating firm will be scheduled in advance, so you will know when to expect the updates. For example, if your manual has not been updated recently, we may assign you to May of 2015. Then your next scheduled update would be May of 2017. (3) Whenever we update your compliance manual, we will send it to you for approval. Once you have approved it, we will provide you with a summary of the changes in the format of a meeting agenda to facilitate the presentation of the revised manual to your entire staff. (4) You will be invited to participate in a semi‐annual “compliance call”, in which PCA staff will highlight hot topics, new rules, trends in regulatory examinations, and other helpful information. The calls will be 30‐45 minutes in length, and will be available “on demand” for replay within 60 days. Semi‐Annual Calls Quarterly Compliance Meeting Agenda and Materials January and July February; May; August; November COST Of course the expense is an important consideration. As always, PCA seeks to provide a cost‐effective and valuable service to our clients that will assist them in successfully managing their compliance programs. Each participating firm will be assessed a quarterly fee of $150. In addition, whenever we need to update your compliance manual, we will assess our normal hourly rates for the services that we perform relating to the update. We anticipate that some updates will be relatively simple and others will be more complex. Every situation is different, so we cannot assign a set fee to this type of service. The real value of this Program is in knowing that PCA will be taking the lead in addressing regular and ongoing updates to your written compliance program. In addition you will have the benefit of participating in the semi‐annual compliance calls as well as receiving the quarterly compliance meeting agenda and presentation materials. We strongly encourage you to consider participating in the Program. Please call us to discuss any questions you may have, or return the attached form to sign up now. PCA’s FOCUS Program Name of Firm:_______________________________________________________________ Contact Person: _______________________________________________________________ Phone Number: Email address: Please list below any immediate concerns you have regarding your compliance manual: ___________________________________________________________________________________ ___________________________________________________________________________________ ___________________________________________________________________________________ ___________________________________________________________________________________ ___________________________________________________________________________________ ___________________________________________________________________________________ ___________________________________________________________________________________ Please provide the date of your last compliance manual update:_______________________________ Once you return this form we will schedule an initial review of your existing manual. If we prepared your manual and you have not made any changes to it, there is no need to send it to us. If you have a manual that another service provider prepared for you (or that you prepared in‐house), please send us the Word document(s) via email (send to [email protected]). By signing below, you acknowledge that you are authorized to enter into a contractual agreement on behalf of your firm. You further acknowledge that PCA will invoice your firm a quarterly fee of $150 as well as hourly fees assessed for compliance manual update work relating to this Program. All terms of the engagement letter with PCA are in full force and effect with respect to services provided under the Program. __________________________________________________ Signature of Authorized Person _________________________ Date ___________________________________________________ Print Name of Authorized Person 7851 Hickory Flat Highway, Suite 200 ~ Woodstock, Georgia 30188
Phone: 678-880-7208
Fax: 678-880-7806