Hello, Welcome to today's webinar where we'll be discussing being getting ready for an audit and how you can proactively be ready for those audits when they come up. I am Jacob Linseth, I am the manager of our SME compliance team and I've got here Connor McDonald with me as well. Every year, the SEC issues its exam priorities as a heads up. These are deficiencies the SEC repeatedly sees during their exams. When the regulators arrive for an exam, if you don't already have your duction row, it's too late. Regulatory agencies have advanced technology to test your confirms compliance program. If you still rely on Excel spreadsheets in an e-mail paper trail to prove your controls, you could be in big trouble. An audit ready firm, by contrast, is ahead of the curve. It has tech solutions that match those of the regulators. It provides end to end compliance support that your whole team can understand, access and easily use. And crucially, it makes reporting easy so you can show your work to the regulators when they arrive. Run Compliance offers an integrated red check solution that covers all of your compliance bases, the hallmark of an audit ready firm. Its features cover all critical compliance elements, empowering CCOS to maintain visibility and control into firm, employee and client compliance matters. Across all these three areas, there are flexible tools you can tailor to suit your firm's unique needs. We're going to walk through some of them today, which include testing forms, personal trading and risk assessment. Orion compliance also offers on demand reporting on all your all of your efforts. So creating the documentation regulator seek is a painless and automated process. Now turn the time over to Connor. All right. Thank you, Jacob. Well, like you said, I am Connor McDonald, I'm VP of Product Sales here at Orion covering the West and central territories. And again, just want to spend a little bit of time with you guys today walking through some of the various components within that Orion compliance tool that can further help you guys to streamline those compliance processes. Make sure that you are doing what you need to do proactively to stay compliant. So as the SEC ramps up their review on practices for data maintenance. You know, as firms, you need to make sure that you ensure you're having tests being completed, you know on these reviews to be able to identify compliance with the policies and procedures, identify your risks and outline how you're going to be able to address those gaps or identify the issues. So let's go ahead and let's jump in and we'll cover some of the items within the compliance tool. So jumping into the system here again we're going to explore some key ways in which this compliance automation software, it's going to be able to support your entire team and maintaining employee and firm wide compliance. So I'm going to go ahead, I'm going to start on this employee side here in cup and touch base on a couple of these different elements, you know on that employee oversight side. And so one of the first one being you know actually being able to monitor their personal training to where we have the ability for these employees to go in. You establish that direct data feed with any of the institutions that they're holding, you know, their personal trading accounts today and then being able to actually have that configured to where employees can get in, submit these trade requests over to the compliance team to review. You know, because we have that direct data feed that's been established, you know as a compliance team we're able to already have to be or already be able to track. You know, what are the recent transactions, what are they holding today, all without having to get any of those manual statements uploaded. Another item that I want to touch on, you know, we obviously want to make sure that we're pushing out these policies and procedures, compliance manuals, you know, out to our advisors so that we know on the employee side, you know, they're able to reference these policies and procedures and make sure that they're staying in compliance as well. This is going to be where our document library comes into play for the employee side where again. Making sure that they have availability to access you know the code of ethics manual, their policies and procedures, you know whatever it may be. The compliance team has the ability to push these out so that they can access them when they need to. Beyond that, you know, we obviously know that the new marketing rule was passed. You know as a compliance team we want to build out those forms and actually make sure that our employees and advisors are leveraging this to be able to submit forms to make sure their marketing material is approved. You know this is where we can make this really easy for them to be able to get in. You know find that form that we have made available to them. So on that marketing side be able to get in and submit that marketing request. And then again as a compliance team building out these forms so that you can identify you know what questions do we need answered from that advisor, you know before they actually submit their marketing material over to compliance or review there. So those are a few different aspects on the employee side. You know, if you'd like to learn a little bit more on, you know the different functionality here, we'd be happy to do this. Do so on a demo for you. But I'm going to go ahead, I'm going to switch gears completely here, going to jump over to the admin side, which would be where a CCO would live. You know that compliance team and really how they can start to automate these compliance processes so that if they ever do get an SCC examination, you know they have this consolidated source to be able to access. Not only any of their tests that are being ran, certifications that are being scheduled, but also being able to report on any of these various compliance activities, you know, within a moment's notice here. So the first thing that I want to touch on really is going to be our calendar piece, which again being able to stay on top of any of these compliance activities that are taking place. So as you schedule out your testing to be ran, certifications go out, you can stay on top of them all directly within this calendar where we can easily keep track of what's coming up. As well as any completion status on those various compliance activities as well One and then jump down to testing, which testing is really going to be if you get an SEC examination. You know these regulators have you know top end technology to be able to get into your system and see you know are you guys doing what you need to do to be able to say compliance approved. And this is really where our testing functionality is going to come into play where you know you're scheduling these tests to be ran to essentially say you know how are we checking that box. So whether it be you know scanning for alternative assets across your book of business, you know making sure that all of your code of ethics are being attested to you know one. Classic example would be e-mail monitoring. So again, when you schedule these tests to be ran, being able to identify not only at the firm but also to your regulators, you know what are the procedures that we have in place today when we're scheduling that test as well as being able to add any additional documentation. You know, while we've ran that test and then being able to document all of our findings here so that when we need to report on these, we're able to pull them out of our reports within the time parameters that we set, you know from a moment's notice there. I'm going to also jump down to forms here. So just to kind of touch on the flexibility that we have in the configuration, you know of these forms themselves. Again as these requests are coming through from your advisors, this is where we can easily access any of those marketing materials that are being submitted by you know, your advisors and you being able to quickly identify, you know what is it that there are, what questions are they responding to based off the form that you've configured. And being able to then add any of your additional findings, you know from that form submission here again we can also leverage our dialogue box here so that if we're wanting to make sure that we're saying compliance approved, we need additional information from you know these advisors that are making these form submissions. You know we can leverage this dialogue box which will essentially e-mail out you know to your advisor that submitted this form saying you know hey we might need additional information surrounding this marketing material request. Once that advisor responds back to that, we're going to archive all of that correspondence directly in this dialogue box. So if you ever have to prove to regulators that you are staying compliant, going through that correspondence, making sure that your advisors are staying compliance approved, you know, we can archive all of that directly in here as well. Again, just to kind of touch on the flexibility of, you know, actually building these forms out and you know, being able to schedule and automate this process for you guys here. And I'd like to touch on an example of the annual code of ethics. So just for example here you know we can schedule this annual code of ethics to be ran whenever we need to. You know we can set due date reminders that are going to come through the employee inbox as well. And then from a compliance side, we can also keep track quickly of you know what advisors have filled out this, you know what is the status of these, are they being completed With each submission that comes through from these advisors, we're also able to quickly access their responses. And add any findings or notes as it pertains to that specific request here regarding the configuration of these different forms. You know obviously as SEC passes new rules or bills then we're going to need to make updates to any of these different certifications or forms. And that's where the power of this tool really comes into play where you know the flexibility of it is pretty unmatched where again we can get in here and we can schedule out what that distribution is going to look like. You know when are those due date reminders coming through the employee inbox. But again, we can also configure these, you know, in a lot of different customizable fashions here. So whether you're building off of, you know, the various certifications of forms that we already have living within the Orion's compliance system today, or importing your question set or modifying this one, you, you have total flexibility and control over how you're making these adjustments, whether you're adding dependencies, changing the question header, reordering things, font. You have that power in your hands to be able to configure these, you know based off these new rules that are being passed to make sure that you guys are staying compliant, compliance approved there as well. I know we touched on the employee side kind of that personal trading. So as those requests come through, you know because we have those direct data feeds, it's going to take a lot of that lift off the compliance team because we have those direct data feeds. We can look at the specific trade request coming from Adam here and again we already are going to be able to pull in their holdings. See any of their recent transactions here And as we're going through this trade request review can document our findings here, finish this review and know that it's being stored so that if we need to report on any of these instances, we can do so from a moment's notice here as well. Also want to touch on the risk module. So we know as a firm, we want to make sure that we're identifying our major risk categories at the firm level and placing those controls in place to help make sure that we're staying on top of them and mitigating that risk as well. That's where the power of this risk module itself will come into play here or just to give you an example of kind of how we can configure that based off what you guys are wanting to do at the firm. In this specific instance, you know we're going to help you guys to identify, you know what are the major risk categories at the firm itself. So in this instance we can see we've identified two major risk categories here, one being books and records, the other being advertising. Based off those major risk categories that we've identified at the firm level, we can then assign risk weightings to them. So whether that be, you know, reputational, mitigated risk, whatever it may be there, we can assign these weightings you know, to these different levels or we can keep it pretty simple where we just assigned one risk weighting through this actual identified major risk category here. And then again once we've built out what that identified major risk category is. Placing in here, what are controls in place to help mitigate that risk? So whether those be testing to be ran, any other controls that you want to associate with this major risk category, you know this can all live within this risk module. And then again who are the responsible parties that are assigned to help mitigate this risk? Assigning these different team members on that compliance side, they have to also take part in helping to mitigate these risks as well. So when we get an SEC examination, you know you obviously want to have kind of that procedures in place to be able to you know quickly identify what you need to do to respond to that. I think that's where the power of this campaign tool will really come into play here where again we can leverage this tool to where if we get an SEC examination we can configure this campaign. To essentially identify, you know if we as a firm get an SEC examination, we have clearly defined procedures in place that as a compliance team we can identify you know what are procedures to go about handling this SEC examination request. Not only that but we can also add in any different controls to actually working through this examination and as we add in these campaign controls. We can assign these responsible parties if we have any approvals, we can assign them, set our due dates here. And then as we're working through these different controls that we've assigned, being able to quickly add updates to them as they're coming through as well as adding any of our findings, notes and attachments all within this specific SEC examination campaign. And so really consolidating all those processes directly inside this instance to make sure that you're working through, you know, these different controls as you see fit there. You know, again with the SEC examination, you know their priorities. You know you are going to have potentially have to make revisions to your policies and procedures, your compliance manuals, you know and that's where our library functionality can really come into play. Where you know with this, this is going to be a great place for you guys to store any of these code of ethics manuals, policies and procedures. You know, build out your folders for where you want to store things. And the power of this too is going to be not only do we store the pre the active version that we have today. But as you guys are making revisions to these different, you know, forms and manuals and we're also going to store any previous versions in here as well. So you know that you have all of your documents whether it's active or previous living within one consolidated place here for you to be able to access when you need to. The last piece that I'd like to end on today is, you know, we touch on, you know how the employees go about making sure that they're staying compliant with submitting their trade requests, submitting their forms. Making sure they're doing what they need to do to partake in, stay in compliance approved and we walked through some of these different tools as far as you know that firm level oversight. So again scheduling your testing, building out your forms and modifying them as needed. You're the last piece that I want to end on is going to be this client oversight tool which is really going to be looking at that back end client and making sure that you guys are doing what you need to do, you know for these back end clients from a compliance perspective here first. First tab here that we're going to kind of explore is going to be this preclearance tab. So if you guys are wanting to build out any specific policies in place for your traders to be able to be notified of whether that be you know like a restricted securities list, you know we have complete flexibility to either build out policies off of ours or create these policies from scratch. Regarding any of these items that might apply to that back end clients, whether it be a restricted list, you know just for an example here. You know this is where we can get in and really start to configure for our traders that are making these trades. You know if we set this restricted list out, you know we can set the system up to be auto reject here, can have the message shown to the traders well when they go to place that trade and then we can get very flexible as far as the policy coverage, policy date range, you know is this going to include all the teams, traders, models, accounts you know or are we wanting to exclude certain you know accounts, traders, models you know from this policy as well? So not only that, but we also are going to on an ongoing basis be monitoring for potentially cheaper share classes. So we know that this is a very cumbersome and tedious process for firms where they're having to, you know, pull, you know, pull manual Excel spreadsheets, go to that custodian, search for cheaper share classes, you know to make sure that you're doing right by your fiduciary responsibility for that client. You know our system's going to do a lot of that for you here to where again you guys can get in and if we ever are notified of you know, our system will identify any potentially cheaper share classes that are available. And this is where we can really get into this and see, you know our system has analyzed and we have a potentially cheaper share class. You know, we can see all the accounts holding it today that would be impacted by this can also see the custodian that's holding that share class today. So we're doing that work for you and then again getting into that. You know, looking at what our system might be recommending to move these clients into, again we can see what that recommendation is here, any of the underlying fund criteria. So if there's a sales load, you know net expense ratios and then we can recommend this to our traders so that we can have that actionable item to send out to our traders to then be able to act on this recommendation, move these clients that are eligible for it into this cheaper share class and make sure we're doing right by the client with our fiduciary duty there as well. Not only that, you know, we're also going to be alerting you guys you know from a compliance perspective of any you know potential ownership or large trader alerts. So really identifying you know 13D and G for ownership, 13H for large trader. Your system's going to also notify you guys of any of those potential alerts that are coming through here. And just to finish this up here on the client oversight piece, again, this risk monitor tool is really going to be where you guys can configure, you know what are the account alerts that you want to be notified of. To make sure you're staying on top of these clients. So whether it's sitting in cash for 10 days, you know you have complete flexibility to adjust that to 20 days, 5 days you know making sure that you guys are being alerted of and staying on top of any of these account alerts as it pertains to that back end client you know with this risk monitor tool as well. I'm very excited to say that we've. Integrated the capability of drift tracking from our risk intelligence tool to where we can get this sinking over here as well. So on that sense again if we have clients you know with a certain risk score and they're drifting away from that based off what they're holding today. You know from a compliance perspective, you know we want to make sure that we're doing right by the client and being notified of that so we can act accordingly to make sure we have the client in these accounts that are best fit you know to that risk tolerance that they have and that's one of the few pieces that we can bring over. From the risk intelligence tool to be able to be notified of here as well. And so then I'm going to finish off again as we go through and we document and automate all these different compliance processes within this tool, You know the back output of this system is going to be again being able to report on these from a moment's notice. So whether that's any trade requests that have come through, you know personal accounts, you know these tests that you guys are scheduling to be ran, you know you want to make sure. That you can pull these documents when you get an SCC examination and have them ready to go. You know this is where the power of the tool really comes into play, where you you get that time parameter from that SCC examination. You know, you guys obviously don't want to stray from those time parameters or else it could potentially open up the box for additional information that you need to provide. So this is really where you guys can set out, you know what are these time parameters in place that we're looking to pull these reports for. You know, and again maybe we want to see, you know, from all these different tests, you know, any exceptions that have been made within this time period. You know, this is where the report, the reporting module itself can automatically pull these. We need to filter them out based off any categories, tags that we've assigned. You know, any officer that's been assigned to it, you know, we can easily filter those out to make sure that we're pulling those reports based off what you're wanting to see there. And I'll end just by showing you an example of report. You have a report from one of these test exceptions themselves, just so you can really see the power of taking all these procedures and findings that you've documented and bullying them all up into one consolidated report for you. All right guys. So like I said, pulling a specific report and getting all this information that we're documenting while we're going through our compliance activities and processes all into one consolidated report here. So again, looking at this specific test that we ran, looking at e-mail monitoring, here again we're able to identify you what was the due date that we assigned for it, what's the period that we're running it for. Based off those document or those procedures that we document in this specific test, your system's going to pull that in as well here on this report. Any categories that we assign, any of those risk weightings that we want to assign will also pull over here as well. And then as you guys are making changes to the status of this, you know whether it's from not started, depending to completed, you know our system's going to time stamp all of this for you here. So if you get that SCC examination you have, you have that clear cut document showing you know we are doing what we need to do to stay compliant. Again, when you document these findings as well we're going to pull those in. We can see that we have an exception here on this specific. You know, tests that we've ran, what's our risk severity level here because we have an exception in this regard. You know, is there any financial impact to the firm here and then what was our resolution that we documented, you know, in this specific test example as well. And then as you guys are going through these different certifications, they're sent out tests that are being ran and you're attaching, you're adding any documents to those instances. We're going to also add those onto these reports as well. So you're not having to go and looking out anywhere else for them. You know we're going to consolidate that all onto any of these various reports that you produce from our compliance tool. So guys that is going to wrap us up here on the compliance tool. Again we just kind of scratched the surface as far as the capabilities of the tool, but we would certainly love from our compliance team to meet with you guys in person, really dive into you know each of these different modules and. You uncover, you know kind of how this functionality can help support your firm from a compliance perspective. So I appreciate the time today. I'm going to turn it back over to Jacob to take us home for today. Connor, thank you for that demo, very indepth and thorough. I appreciate it. We're going to transition into some Q&A now. So I'm going to ask Connor the first question. Connor, how does Orion compliance integrate with the rest of my tech stack? Yeah, great question. So there's a couple different ways in which we integrate. I'd say one of them being you know, kind of on that personal trading side. So with these the back end clients that you have at Orion that you guys are working through your processes on, you know setting up these different policies to help you guys monitor for potential front running. You know, I'd say that's one component to how we integrate with them. I'd say another piece would be on that testing side to where you know we can actually establish data queries within the Orion. You know, connect core system and then actually hyperlink those into those tests that you guys are being ran to where when you want to run a test for, you know let's say you want to scan for any alternative assets on a monthly basis. You know we can schedule those queries to be ran out inside Orion Connect itself so that when you're going to do that test you automatically have that query to be ran to pull up that list. And then be able to document your findings there. And then last I think I'll finish on you know really that client oversight piece. So you know as we're building out any of these policies so like the restricted security list for example, you know leveraging the Eclipse trading rebalancing platform inside Orion Connect itself and we can configure these policies in that client oversight tool to whereas your traders are going through and making these trades based off the policies that you set, you know they can be notified of if they're. You know, actually going and you know this is trading on a restricted securities list. For example, you're making a model update with the restricted security and customizing that message to be able to show them while they're going through their daytoday trading you know within the Eclipse trading rebalancing platform. All right. So Jacob, looks like we have another question here which is going to be, you know, our legacy compliance processes are pretty ingrained. Will Orion assists me in migration, getting things set up and or educating you know their team during the onboarding process? Sure. Great question. My team, the SMU compliance team, we have a very extensive onboarding process. We'll walk you through getting things set up. We have some templates to import your users and then your different accounts to then be able to submit your accounts to different brokers and we'll walk through all that process and. Getting your different certifications, whatever forms you need, we walk through all of that to help you get that all set up in the system. Great, Thanks for that. And then Jacob, I will finish with one last question here. We'll let you take us home for the day which is how it easy is it to adjust the Orion compliance system over time. So to meet you know as we've talked through you know these new SEC exam priorities to help meet these new regulatory requirements. And or as their internal processes change over time, Sure. Great question again. So as you were showing during the demo, you know the the system is very flexible, so you can customize things whoever, whoever you want to do it. You know considering you know your internal processor is changing or the regulatory requirements are changing. We also have a dedicated product team who's who's keeping an eye out on. On the horizon for different changes that may be coming you know from from the regulators and we we try to keep those in in in view when we do, when we do make updates or enhancements to the system as well. Thanks everybody for attending today's webinar. If you have questions or you want to schedule a demo reach out to the e-mail that's on your screen right now and we'll get that set up for you. Have a great day. Thanks everyone. _1713913709759

Get Audit-Ready: How To Prepare for an SEC Exam Proactively

The SEC releases its annual Exam Priorities as a heads-up to advisors and firms. It sees the same deficiencies time and again, and it’s issuing a message: Don’t let this be you.

When regulators arrive at your doorstep, they’re armed with advanced technology to assess the strength of your compliance program. If your internal systems are outdated or ineffective, they’ll spot it. Fast.

You need an integrated, end-to-end regtech solution to put you on equal footing with the regulatory agencies. That’s how you deliver the kind of always-on compliance program they expect to see, with the audit trail that shows it!

Join Connor McDonald, VP of Product Sales at Orion Advisor Tech, and Jacob Lindseth, SME Compliance at Orion Advisor Tech, as they demonstrate exactly how you can use the flexible solutions Orion Compliance offers to build an audit-ready compliance program that suits your firm.

0927-OAT-3/31/2023

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