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Consulting

Client Assessment

On-Call Consultation and Research

Fiduciary Assessment

Risk Management Analysis

Compliance Services

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Compliance Policies and Procedures Drafting

Compliance Audits and Mock Regulatory Examinations

Compliance Training

Consulting

Compliance Assessment Services

Evaluation
HRL evaluates and determines the client organization’s conformance to relevant regulatory obligations. This determination includes the self-regulatory, state and federal regulatory and compliance regimen. Compliance assessments may be performed in an on-site or off-site capacity, largely dependent upon the scope and size of the business, geographical dispersion of personnel, and the nature and urgency of client requirements. The assessment process entails a review of primary compliance capabilities and related business operations.
Components of the client compliance infrastructure reviewed often include:
- Written policies and procedures
- ADV Form Parts I and II or Form BD
- Client contracts, applications, disclosures, and related account opening documentation
- Third party relationships and contractual obligations
- SEC, NASD, and/or state securities commission examination findings
- Other areas of interest deemed relevant to the compliance program
A findings and recommendations report is issued upon completion of the compliance assessment. HRL remains available to assist clients in implementation of recommendations.
On-call Consultation and Research Services

HRL offers timely on-call compliance consultation and research services on an as-needed and confidential basis. We recognize that our clients may be short on time and resources when it comes to researching and resolving “in the moment” compliance questions and issues. The resources we offer allow our clients to focus on their core business – serving their clientele.

Fiduciary Assessment Services

Litigation of fiduciary breaches of obligation continues to rapidly increase in the financial services marketplace. The HRL fiduciary assessment service focuses exclusively on the fiduciary obligations posed to our clients by virtue of their business model. These obligations are manifest primarily as management of conflicts of interest, ongoing third party due diligence processes and related client disclosure protocol. The fiduciary assessment is performed with an on-site review of relevant business documentation and practices, utilizing analytical tools and methodologies developed by fi360, in conjunction with the Center for Fiduciary Excellence (“CEFEX”).

Risk Management Analysis Services

Client interest may center upon specific, non-systemic compliance concerns pertaining to a particular compliance process. HRL provides targeted risk management analysis and resolution capabilities pertaining to all aspects of the client compliance infrastructure. We have delivered risk management consulting services on a broad range of issues, to include for example business resiliency, and line of business trading risk.

Compliance Program Design, Audit and Implementation

Compliance Policies and Procedures Drafting Services

Investment Advisers
HRL offers customized policy and procedure drafting services to meet regulatory requirements. We have worked with start-up and seasoned advisers in building compliance policies from the ground up, as well as firms seeking to expand and/or overhaul existing programs.

Investment advisory practice areas of import in a compliance policy and procedure program include: role and activities of the Chief Compliance Officer, portfolio management processes; trading practices; personal trading and conduct of advisory persons; public disclosures, marketing material, and solicitation arrangements; safeguarding of clients assets, information and records; creation and maintenance of books and records; portfolio valuation and fee assessment practices; third party arrangements, and business continuity plans.

Broker-dealers
HRL offers policy and procedure drafting and review services to ensure that clients are fully compliant with relevant rules, statutes, and regulatory guidance. As necessary, HRL drafts customized policies and procedures to fill evident gaps and deficiencies.

Broker-dealer compliance policies and procedures are customized to meet the unique requirements of each client firm, based on their business model, client base, products and services, and regulatory status. A sample of compliance focus areas includes registration; supervision and delegation of duties; anti-money laundering; privacy and safeguarding of assets; customer accounts, transactions and holdings; customer communication and complaints; business and financial risk management; books and records; order handling and trading; underwriting, research; sales, advertising and marketing; business continuity planning; and product-specific requirements.

Compliance Audits and Mock Regulatory Examinations

HRL offers audit and mock regulatory examination services designed to ensure that registered investment advisers and broker-dealers meet continuously evolving regulatory requirements – directly helping them protect and expand their business and reputation. HRL audit programs offer objectivity, expertise, and timely assistance in the ongoing monitoring of a firm’s compliance program.

The audit process mirrors the compliance assessment model, but is designed to be more in-depth and inclusive with regard to the operations of the firm. Audit and mock regulatory examinations incorporate testing of the compliance program to ensure its effectiveness and adequacy. HRL evaluates the operational efficacy of the various components of a firm’s compliance policies and procedures. In-depth staff interviews are conducted to gauge the compliance knowledge and compliance involvement of personnel.

HRL replicates the regulatory inspection model applicable to the firm (SEC, NASD, or state securities commission) to the extent desired by the client. Upon audit completion, HRL issues a thorough findings and recommendations report and stands ready to assist clients in correcting compliance deficiencies and mitigating compliance risks.

Compliance Training

HRL offers customized training solutions to help clients nurture a compliant culture. Services and programs include:

Development of Firm Element Continuing Education Needs Analysis and Training Plan
Annual Compliance meeting content development and delivery
Compliance Policy and Procedure training
Regulatory audit / inspection preparedness training
Audit findings and solution implementation training
Anti-money laundering and privacy training
Product-specific education

Horrigan Resources, Ltd.
3000 Village Run Road Building 103, #209, Wexford, PA 15090 Phone: 724.934.0129 Fax: 724.934.0132	Sign up for our Email Newsletter
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