Policies and Procedures / Compliance Manual: The firm s Policies and Procedures manual is the guiding document that

your firm w ill use to maintain and enforce your firm s internal policies on all aspects of yo ur business from the handling of client complaints to the training of new Invest ment Adviser Representatives. It also houses your firm s Business Continuity Plan, Privacy Policy, Anti-money Laundering Policy, Anti-insider Trading Policy, etc. RIA In a Box will work with you to create a robust manual that is also a usable tool written in plain English and easily navigable. This is a very comprehensive , tailored document that will be the foundation of conducting advisory business in a compliant manner. Adding Additional States: While the description of your firm s services and fees should remain constant acro ss the jurisdictions (states) in which the firm is applying, different jurisdict ions can have vastly different disclosure requirements. RIA In a Box will guide you through this process, creating and amending documents so that they are in co mpliance across all state jurisdictions. A registered investment adviser must generally register in any state in which it has a physical location, a representative physically located, has 5 or more cli ents (or just 1 client in regards to Texas and Louisiana), or has boots on the gr ound soliciting in the state. A handful of states require registration even if an RIA is only soliciting in the state remotely. Adding Additional Representatives: All representatives of your firm need to be registered to the RIA if they are pr oviding or generating advice. In general all executive officers or people who ha ve Control of the RIA should also be registered to the firm. Registration includ es filing a U4, ensuring the testing requirements or testing exemptions are sati sfied, creating an Form ADV Part 2B brochure supplement and, in most cases, uplo ading that the ADV Form Part 2B to FINRA s WebCRD system.

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