Compliance Procedures
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SEC Requirement
The SEC Compliance Program Rule requires all advisers registered with the Securities and Exchange Commission (“SEC”) to adopt policies and procedures that take into consideration the nature of that firm's operations. The policies and procedures should be designed to prevent violations of the Advisers Act from occurring, detect violations that have occurred, and correct promptly any violations that have occurred.

The SEC expects each adviser in designing its policies and procedures, to first identify conflicts and other compliance factors creating risk exposure for the firm and its clients in light of the firm's particular operations, and then design policies and procedures that address those risks. In the adopting release to the Compliance Program Rule the SEC set forth a number of areas that most advisers should address in their policies and procedures.

SCA Response
SCA has developed best practices for the areas covered in the Adopting Release and other areas that may represent conflicts of interest for many firms. These procedures are revised frequently by SCA based upon information coming out of the SEC, enforcement actions, and input from our clients.

We are known for providing comprehensive customized procedures to our clients that incorporate the best practices for each firm with the compliance infrastructure already in place. For start ups we spend time trying to understand the advisory practice and design procedures that will address those areas where conflicts are most likely to arise. Our procedures have withstood SEC inspections since the Compliance Program Rule went into effect.

For those firms that wish to design their own compliance program we will sell our best practices for use as a guide. We discourage any firm from purchasing an “off the shelf” compliance manual unless they plan to customize.