On October 26, 2022, the Securities and Exchange Commission proposed new oversight requirements for certain services outsourced by Investment Advisers. https://www.sec.gov/news/press-release/2022-194

The new rule proposal would prohibit registered investment advisers from outsourcing certain services and functions without conducting due diligence and monitoring of said service providers.

The outsourcing focus is on areas such as:

  • Outsourced Compliance Consulting
  • Outsourced Chief Compliance Officers
  • Investment Guidelines
  • Portfolio Management
  • Investment Modeling
  • Indexes
  • Trading Services
  • Software

The new rule proposal would require initial and ongoing due diligence, maintaining books and records (documentation) relating to your due diligence, disclosing on your form ADV about certain service providers,  and more.

Our Simple Compliance Portal already contains a Simple Vendor Due Diligence form to collect and document your vendor due diligence along with many other compliance forms for documenting your compliance program.

Do you have a solution for documenting your due diligence vendor reviews?  If not, schedule a call with us to discuss options on how we can help you check this task off your compliance calendar.