Charts And Graphs
When putting together visual communications, do a thorough job of labeling charts and graphs, added Anderson. Disclose all sources of information. Make sure the end reader has a clear understanding of what they are looking at.
Internal Standards
Every advisor needs to ensure that there is a set of policies and procedures that governs the client communications within the firm, said Anderson. That includes a “review and approval policy.” There needs to be a clear definition of how the content is going to be reviewed so the chief compliance officer can find any gaps or noncompliance of the procedures.
There should be a “performance calculation policy” to determining the parameters for performance calculations and for checking the accuracy of the performance results.
All of the communications, as well as the performance source and back-up for each of the communications, should be retained for five years after the date of last use. There should be easy access for the chief compliance officer to access any of this information that might be asked for during a SEC examination.
Mike Byrnes is a national speaker and owner of Byrnes Consulting LLC. His firm provides consulting services to help advisors become even more successful. Need help with business planning, marketing strategy, business development, client service and management effectiveness? Read more at ByrnesConsulting.com and follow @ByrnesConsultin.