In connection with the supervisory compliance controls of Rule 206(4)-7, SEC Final Rule Release IA-2204 and corresponding SEC guidance, firms must:

• implement internal compliance controls designed to detect and prevent regulatory violations;
• establish supervisory policies and procedures for all business-related communications with clients, including:
  • methods of detecting and addressing regulatory violations in electronic communications, and
  • restricting such communications if they cannot be adequately archived and supervised;
• implement safeguards to protect the privacy of client records and information;
•  monitor the accuracy of disclosures made to investors, clients and regulators, including account statements and advertisements;
• implement controls for the accurate creation and maintenance of required records in a manner that secures them from unauthorized alteration or use and protects them from untimely destruction;
• annually review written supervisory policies and procedures
• designate a chief compliance officer to administer the supervisory compliance systems; and
• implement an annual review system and ensure the ability to store review results.