Silver Services

Silver Registration and Foundation Services

  • Creation and filing of Form ADV
  • Compliance risk review
  • Custom Compliance Manual/Code of Ethics with only relevant policies and procedures
  • Tools that work, including a compliance calendar tailored to firm compliance program and business practices
  • Firm marketing material and website review
  • Initial training session for all staff
  • Creation and filing of SEC Form BD and FINRA Form NMA
  • FINRA-mandated Written Supervisory Procedures tailored to applicable FINRA requirements
  • Tools that work, including a compliance calendar tailored to firm supervisory procedures and business practices
  • Employee FINRA registration advice and process coordination
  • Firm marketing material review
  • FINRA-mandated Continuing Education Program and an initial training session for all staff
  • Attendance and support at meetings with regulators

Silver Maintenance Services

  • Compliance risk, infrastructure and program and website review
  • Compliance calendar tailored to firm compliance program, business practices and testing and exam history
  • Management of Form ADV, Form PF and Compliance Manual updates
  • Employee Code of Ethics disclosure review – personal trading, outside business activities, political contribution and gifts/entertainment
  • Quarterly marketing material review
  • Assistance with committee meeting preparation and documentation
  • Annual Review, including testing, a findings report and recommendation implementation 
  • Annual training session for all staff and new employee trainings
  • Regular updates on industry developments, deadline reminders and probing for new regulatory implications
  • Access to Silver senior members for ongoing advice
  • Compliance infrastructure and program review
  • Compliance calendar tailored to firm compliance program, business practices and exam history
  • Management of Form BD, FINRA membership and Written Supervisory Procedures updates
  • Employee Code of Ethics disclosure review – personal trading, outside business activities and gifts entertainment 
  • Marketing materials review
  • Annual Review, including testing, a findings report and recommendation implementation 
  • FINRA-mandated Continuing Education Program, an annual training for all staff and new employee trainings
  • Regular updates on industry developments, deadline reminders and probing for new regulatory implications
  • Access to Silver senior members for ongoing advice

Silver Specialty Services

  • With an array of crypto/digital assets clients, Silver is adept at navigating the regulatory nuances facing these firms
  • We determine whether and which regulations apply
  • At the forefront of developing best practices for the asset class, we find compliance approaches that fit
  • To address increased investor focus on ESG integration and reporting, Silver develops and maintains ESG programs
  • We compare a firm’s current ESG efforts to best practices and develop/implement policies, procedures, reporting tools and trainings    
  • Silver responds to ESG-related DDQ questions, manages internal and external ESG reporting and updates firms on ESG developments
  • Expense allocation
  • General solicitation and marketing
  • Pay to play  
  • Information security

Silver Assessment Services

  • SEC Responsiveness Reviews – Test document production and prepare firms for regulator interview
  • Mock SEC Exams – A deep dive probing, like regulators, for weaknesses
  • Thematic Gap Assessments of specific firm practices – Expense allocation, marketing, custody rule, best execution, investment allocation and aggregate and inside information practices
  • Infrastructure Assessments – Compare a firm’s compliance resources to its competitors’ resources
  • Findings Implementation – Silver brings its calibrated approach to effect recommendations made by Silver or another company

Silver Exam Support Services

  • Silver explains the process and prepares firms for regulator interviews
  • We assist with initial document production and follow-on requests
  • Post-Exam, Silver helps with deficiency letter responses and new disclosures, policies and procedures