5 Steps For Taking Control Over Your Compliance Tasks

Staying on top of your compliance tasks and responsibilities as an RIA can often seem overwhelming – especially for those whose compliance accountabilities are only part of their role. This business area may often seem the least exciting and have the least amount of management training or experience. At XYPN, we support many advisers in putting efficient and effective compliance policies and procedures into place and refining various aspects of their compliance program to know what to do when they need to do it and how to ensure it's done correctly. This is where compliance task management systems, such as Smartria, come into play. 

Below, we highlight best practices from XYPN’s Compliance Consultants to help you get and stay on track, especially when using Smartria to manage your compliance tasks.

Step 1: Set a realistic cadence for managing your compliance tasks and stick to It

Consistency in managing compliance tasks is crucial. Set a cadence that works for your firm based on the amount of supervision involved, the scope of advisory activities requiring monitoring or reviews, and the number of supervised persons. Schedule time to review your compliance tasks weekly, monthly, or sometimes even quarterly, and stick to it. If your firm’s practices change, you hire more staff, or you find deficiencies in certain areas, adjust the frequency and depth of your review activities and update related policies as needed.

Step 2: Tailor Policies, Procedures, and Compliance Tasks to Fit Your Firm’s Compliance Needs

It is common for RIAs to work with consultants to adopt policies and procedures for their firm, and in many cases, these policies and procedures need to be reviewed and tailored to address the needs of each firm. A common deficiency amongst many states or with the SEC includes insufficient or irrelevant compliance policies that often step from using “off the shelf” compliance manuals. Whether you are working with XYPN’s Compliance Team or another compliance firm, review and customize your compliance policies to align with your firm’s operations and compliance needs.

This helps to ensure that you do not have unnecessary compliance tasks that do not apply to your firm and have reasonable processes put into place for those that do apply – saving you time and work later on while providing you greater confidence in your compliance program. If you haven’t engaged with a compliance consultant for support in this area, we recommend working with one to ensure an efficient compliance program to customize your compliance tasks for your firm and your primary regulatory jurisdiction.

Step 3: Adding your Compliance Tasks to your primary Calendar

Place your compliance tasks where you keep track of your responsibilities, meetings, and other reminders. If you use Smartria, you can export your compliance calendar to your primary calendar, such as Google or Outlook, from the Master Calendar page within the Smartria app. This allows your compliance tasks to be linked and updated directly in your primary calendar, making task reviews easier to keep on top of!

Being aware of deadlines without logging in regularly boosts efficiency and helps you stay organized.

Step 4: Group or Batch Task Dates for Efficiency

If you complete your compliance work in batches or larger blocks of time, it can make sense to group tasks around similar dates so that they show up simultaneously, especially those similar or related tasks.

For those tasks that are related and if you intend to complete them at the same time, you can consider combining them by creating a single task that describes the total scope of work rather than keeping them as separate tasks, such as “Review Code of Ethics, Business Continuity Plan, and Data Security Manual for continued adequacy.” This can help you streamline workflows and reduce clutter, allowing you to focus on completing everything without missing details or duplicating efforts.

Step 5: Don’t Get Overwhelmed by Past-Due Tasks – Set a plan to get back on track and move forward

Often, with small and solo-adviser firms, advisers get seemingly way off track with specific tasks scheduled in Smartria or similar systems. This often occurs due to not establishing a reasonable cadence, not tailoring the task details, and recurring cadence to the needs of your firm. It is easy to get overwhelmed when you see a growing list of overdue tasks and aren’t sure where to start or how to move forward. It is important to remember these task management systems are simply that – task management systems. They do not replace your compliance manual or other policies and procedures but provide a framework to help you manage your compliance obligations more effectively continuously.

If you get off track, take a moment to pause, evaluate the top priority tasks for your firm (those with more risk of missing something essential or those with regulatory deadlines), and commit to a plan on getting those on track moving forward. Review your compliance manual for the areas related to the off-track tasks and determine if you have record-keeping issues due to not completing a task. In those cases, do what you can to gather the required records for the impacted time frames. 

In most other cases, for areas where you indeed haven’t focused on the compliance aspect, let's say, for example, tasks associated with advertising reviews, contract execution reviews, or reviewing your trading policies and procedures – You should evaluate what all has taken place in the connected areas of your business in the past year and make an honest assessment of the need for retrospective reviews to get caught back up with confidence and determine how much to extend the scope of those tasks moving forward to capture enough of the historical activity to be confident that your firm is operating in a compliant manner in each of those areas.

Smartria’s core task management module is designed to help you stay on track with ongoing compliance tasks. Using it consistently and ensuring your tasks are reasonably tailored for your firm and compliance program will increase your confidence when an audit comes up.

By reviewing your tasks regularly and sticking to a manageable schedule for completing them, you’ll likely have reviewed and corrected many issues in areas that regulators would be reviewing during an examination anyway. It’s better to be proactive in addressing any gaps or deficiencies in your compliance program that you discover rather than waiting for an audit to uncover them.