Our Services
Horrigan Resources provides a variety of service options for our clients.
Investment Adviser Registration and Transition Services
We provide start-up services for newly formed investment advisers. Deliverables include Form ADV preparation and filing, compliance program development, and compliance orientation training to support the successful launch of a new advisory business.
Horrigan Resources also serves Exempt Reporting Advisers through the transition to full adviser registration status. Services include Form ADV application, and compliance program build-out.
Investment Adviser Compliance Program Implementation
We support ongoing implementation of an adviser’s compliance program. Ongoing implementation flexes to meet each adviser’s unique support needs.
Annual Compliance Reviews and Compliance Risk Assessments
Business and regulatory evolution can overtake even the most diligent Chief Compliance Officer. We prepare annual compliance program reviews to meet Rule 206(4)-7 requirements and compliance program risk assessments to evaluate the effectiveness of an adviser’s program.
Compliance Policies and Procedures
We offer customized policy and procedure drafting services to meet regulatory requirements. We have worked with start-up advisers in building compliance policies from the ground up, and seasoned firms seeking to expand and/or overhaul existing programs. Investment advisory practice areas of import in a compliance 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 promoter arrangements; safeguarding of clients assets, information handling and security; creation and maintenance of books and records; portfolio valuation and fee assessment practices; third party service providers; and business continuity plans.
On-Call Services
Even the most seasoned Chief Compliance Officer can benefit from an independent, objective compliance sounding board. Client inquiries are fielded by seasoned principals as they emerge, billed at a predetermined hourly rate.
Web-based Compliance Tool
comport365® is a software application which introduces very significant efficiencies to your firm’s compliance program. Designed by Horrigan Resources for investment advisers and private funds, this compliance tool captures and monitors compliance events ranging from procedure testing and office inspections to regulatory filings and training sessions. comport365® provides a venue for the compliance team and line of business professionals to monitor and communicate about compliance matters. comport365® supports the annual compliance program review for advisers, as all records pertaining to compliance activities are consolidated within the tool.
SEC Mock Audits
Broadway actors do it, the Navy Seal Team does it … and your firm can do it too. A dress rehearsal for the SEC examiner is a valuable exercise. We review all primary compliance documentation for congruence with the adviser’s business model and regulatory requirements. Findings and recommendations reports are delivered in oral or written form. We then assist clients in deficiency and gap remediation as necessary.
Compliance Training
We offer customized training solutions to help investment advisers nurture a compliant culture. Programs include:
- Annual compliance meetings
- Topical compliance training
- Regulatory examination preparedness training
- Audit findings and solution implementation training
- Newly registered adviser compliance orientation