New Adviser Setup

We take the guess work out of meeting the initial regulatory requirements. Focus 1 will work with your compliance/management team to provide assistance with the following:

• ADV Parts 1 & 2A filing
• ADV Parts 2A and 2B development
• Code of Ethics development, in accordance with Rule 204A-1 of the Investment Advisers Act and 17j-1 of the Investment Company Act of 1940
• Policies and Procedures development, in accordance with the areas the SEC has identified in the adopting release of Rule 206(4)-7 as applicable to your firm:

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  • Portfolio Management
  • Accuracy of Disclosures
  • Proprietary Trading
  • Safeguarding of Client Assets
  • Books and Records
  • Safeguards for Privacy Protection
  • Trading Practices
  • Marketing Advisory Services, Including Solicitation
  • Valuation of Client Holdings and Assessment of Fees
  • Business Continuity Plans

Note: FOCUS 1 will address any additional procedures deemed necessary such as Proxy Voting, Political Contributions and Identity Theft/Red Flags rules

• New Adviser Examination Request Letter review, to ensure your firm is ready and able to provide the necessary documents.