Copyright 2024 ORICAL LLC - Partner - Florio Leahy LLP (Affiliated Law Firm, Attorney Advertising)
Orical provides expert compliance and risk management services, customized to meet the unique needs of investment managers. Our experienced team helps firms optimize their regulatory practices and achieve operational efficiency through tailored strategies and advanced software solutions.
Registration Services (RIA, CPO/CTA, B/D)
We eliminate start-up costs associated with registration by including a full suite of registration services under our retainer-based fee program, including all parts of Form ADV and developing customized compliance policies. Orical’s team of industry-experienced investment management professionals has extensive experience registering investment advisers with the SEC and state regulators. We are uniquely positioned to register investment advisers following the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act. We have helped numerous firms navigate the registration requirements for the first time.
The in-house industry experience of our professionals enables us to provide investment advisers with timely, practical advice and hands-on assistance with a unique understanding of today’s issues facing investment advisers. We understand the costs of obtaining quality advice and help from another experienced professional are often unpredictable and expensive. We typically negotiate cost-effective flat rates for our services, from the initial investment adviser registration process to monthly flat rates for compliance monitoring and advice. Such services include the development of customized compliance programs, compliance manuals, code of ethics, and other compliance documentation, as well as the conducting of mock audits pursuant to the regulations of the SEC, CFTC, NFA, and FINRA.
For any registration inquiries, please reach out to us at info@orical.org. One of our experienced professionals will respond promptly.
Personal/Firm Trading & Conflict Reviews
At Orical, we understand the amount of time, energy, and organization it takes to monitor your firm’s compliance program. We created our in-house compliance administrative software, REAL World Compliance (“REAL”), to provide our clients with a cost-effective, efficient way to review personal/firm trading activities and conflicts of interest.
Our hands-on team of compliance experts provides custom reviews of personal trading activity, potential conflicts of interest, and outside business activities based on your firm’s risk profile and policies and procedures. We also review electronic communications for personal/firm trading activity, potential conflicts of interest, and outside business activities. Using our cutting-edge technology, Orical can help prevent and protect your firm from potential trading violations, including insider trading.
For additional information on Orical’s personal trading and conflict reviews, please contact us at info@orical.org. One of our experienced professionals will respond promptly.
Assistance with Regulatory Exams
With former prosecutors and CCOs on staff, Orical has assisted its clients through hundreds of actual exams and conducted a similar number of mock exercises. We often provide actual in-exam assistance through our affiliated law firm, Florio Leahy LLP, whose product is subject to the rules that govern attorney/client privilege (Attorney Advertising). In today’s regulatory environment and with an increasing number of registered investment advisers, the amount of regulatory examinations by the SEC has increased. SEC examinations and onsite visits can be highly time-consuming and disrupt a firm’s day-to-day operations, lasting anywhere from a few weeks to multiple months.
Orical’s team of attorneys and compliance experts has years of experience assisting investment managers and funds with regulatory examinations and has gone through hundreds of examinations. We assist clients in all aspects of exams, from responding to document request lists to preparing your team for onsite visits.
For questions or assistance with regulatory examinations, please contact our affiliated law firm, Florio Leahy LLP, at https://www.florioleahy.com/ for more information.
Compliance Policy Advice & Drafting
Orical’s team has decades of experience writing clear and effective compliance policies and procedures, representing the industry’s best practices, to ensure compliance with applicable rules and regulations.
Policies include, but are not limited to:
If you or your firm need help to draft compliance policies or have questions about which policies to comply with, please reach out to us at info@orical.org. One of our experienced professionals will respond promptly.
Electronic Communications Review
Orical can conduct thorough reviews of your firm’s archived electronic messages (emails, social media messages, Bloomberg messages/IMs, etc.) on a quarterly and as-needed basis. We use random sampling and intelligent keywords based on your firm and market data (e.g., professional sporting events, significant trades, attribution, etc.), in addition to other specified requests.
We customize our reviews to your firm’s electronic communications policies, conflict policies, and risk profile. We select custom key works designed to identify potentially undisclosed conflicts and compliance with the various requirements of your firm’s policies and procedures, including the code of ethics. Orical can conduct electronic communication reviews on any online archive that your firm chooses.
For additional information on Orical’s electronic communications reviews, please reach out to us at info@orical.org. One of our experienced professionals will respond promptly.
Compliance Training & Periodic Regulatory Updates
Orical provides compliance training for all members and employees of your firm. Compliance trainings are led by our investment management attorneys and a partner. Orical provides firmwide training sessions at least annually and on an as-needed basis, including new employee training and adviser onboarding.
Orical works with your firm to create a customized, practical training session for your team. Training topics typically include but are not limited to: investment adviser’s code of ethics; anti-insider trading policies; current SEC regulatory updates and trends; trading and allocation practices; disclosure requirements; privacy, confidentiality, and protecting firm and client property; cybersecurity; advertising and performance reporting; expert networks; electronic communications; media communications/relations; reporting of violations and whistleblower policies.
Orical also provides periodic regulatory updates to our clients, including CCO Alerts, overviews of SEC Regulatory Updates and Enforcement Actions, and other notable alerts and publications to keep you up to date with the industry’s latest laws and regulations.
For more information on our compliance trainings or to sign up for our emails and publications, please reach out to us at info@orical.org. One of our experienced professionals will respond promptly.
Code of Ethics Administration
Orical provides a cost-effect, custom code of ethics administration to fit any firm’s compliance program and budget. Our in-house compliance software, REAL World Compliance (“REAL”), provides an automated, firmwide code of ethics monitoring, reviewing, and archiving all on a single platform. Code of ethics administration capabilities include documentation, tracking, review, and downloading of:
Mock Audits & SEC Exam Readiness
Conducting a mock audit is an important exercise to review and test your firm’s compliance program thoroughly. With former prosecutors and CCOs on staff, Orical has assisted its clients through hundreds of actual exams and conducted a similar number of mock exercises.
If you are an SEC-registered investment adviser, you are required to comply with the Investment Advisers act of 1940 (the “Adviser’s Act”). Rule 206(4)-7 under the Adviser’s Act requires investment advisers registered with the Commission to adopt and implement written policies and procedures reasonably designed to prevent violations of the federal securities laws. The Rule also requires advisers to review and test, at least annually, compliance policies and procedures and their implementation for adequacy and effectiveness.
Today’s sophisticated investors and regulators expect investment advisers and broker-dealers to employ compliance and operational infrastructure capable of detecting and preventing fraud and misconduct. Investor expectations and current regulations require firms to test periodically and fully document their compliance and control procedures.
Many investors and accepted industry best practices require that an adviser’s annual compliance testing be conducted and certified by an independent, third-party firm. Our compliance monitoring and mock audit programs provide an extra level of investor and client confidence and add that measure of independence expected by investors and regulators. All audit and monitoring program starts with a thorough risk assessment of all critical areas and appropriate firm infrastructure.
For any mock audit inquiries, please reach out to us at info@orical.org. One of our experienced professionals will respond promptly.
CCO Training Programs, Guidance & Education
Orical works with many new and established firms and Chief Compliance Officers. Our job is to help your firm’s CCO and compliance team be well educated and equipped with the tools and resources needed to upkeep and monitor a compliance program representing the industry’s highest standards.
Orical also provides our clients with periodic regulatory updates, regulation summaries, and publications to keep their compliance teams educated and updated with the industry’s latest laws and regulations. Our publications include CCO Alerts, Orical Regulatory Updates, and other alerts and white papers.
For more information on CCO trainings or education, please reach out to us at info@orical.org. One of our experienced professionals will respond promptly.
Assitance with all Regulatory Fillings
The regulatory filings requirements for investment advisers can be costly and confusing, making it difficult to meet regulatory filing deadlines and file complete and accurate information. Orical’s team of experts has years of experience with preparing, drafting, reviewing, and filing SEC, CFTC, NFA, and FINRA regulatory filings, including Form ADV, Form PF, Form D, Section 13 & 16 Filings (Schedule 13D, Schedule 13G, Form 13F, and Form 13H). Our team assists with filings and helps your firm manage these complex reporting requirements at an affordable, flat rate.
If you have any questions on regulatory filings, please reach out to us at info@orical.org. One of our experienced professionals will respond promptly.
Compliance Monitoring Programs
Our compliance monitoring programs provide our clients’ full-time personnel the increased bandwidth to manage client assets and raise capital. Clients receive quarterly confidential compliance reports summarizing the procedures performed and policies reviewed, disclosing results, and certifying that procedures are conducted according to the program’s agreed-upon procedures and represent the applicable industry’s best practices. We utilize cutting-edge technology to efficiently administer your firm’s complete codes of ethics and additional compliance responsibilities. We cater to the needs of our clients by providing the option of flat and affordable monthly rates.
Our compliance monitoring program has continuously proved to be the desired measure of investor confidence and independence to its clients’ compliance and operational procedures. Our experienced professionals will answer operational, trading, and compliance questions and issues quickly and confidentially.
To view a sample of our compliance monitoring programs, please contact us at info@orical.org.
