Registered Investment Advisers

ITA Compliance, LLC provides independent testing services to SEC Registered Investment Advisers (RIAs) located throughout the United States. Our clients’ businesses vary by factors such as by number of employees (1-500+), assets under management, types of clients/investors, custody arrangements, investment products and strategies, and affiliations with other investment-related businesses.

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Services Offered

Annual Compliance Reviews (Rule 206(4)-7)

ITA Compliance, LLC reviews written policies and procedures to determine whether they are adequate, customized to the firm’s business, and properly address regulatory requirements. In addition, ITA Compliance, LLC evaluates the related books and records required by your compliance program. The testing scope for these reviews commonly includes:

Forms ADV and CRS

Conflicts of Interest

Investment Advisory Agreements

Portfolio Management

Trading

Custody

Advertising

Correspondence

Business Continuity Plan

Code of Ethics

Third-Party Vendors

Privacy and Regulation S-P

Cyber/Information Security

Employee Training

Correction of Past Internal and SEC Deficiencies

Other areas included in the firm’s compliance program and/or determined by a risk assessment.

Department of Labor (DOL) Prohibited Transaction Exemption 2020-02 (PTE 2020-02)

Since 2023, ITA Compliance, LLC has conducted the annual retrospective review required by DOL PTE 2020-02. This review assists firms to ensure they are in compliance with the new exemption and also supports the senior management certification which is required within six months of the end of the testing period. ITA Compliance, LLC’s PTE 2020-02 annual reviews consist of evaluating the following:

Written Policies and Procedures

Client Disclosures

Impartial Conduct Standards

Rollover Recommendations and Analysis

Eligibility Provision

Prior PTE 2020-02 Review and Certification

Remediation of previous internal and regulatory findings, if applicable.

For Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs)

Anti-Money Laundering Testing

As required by FinCEN’s final rule, investment advisers (including exempt reporting advisers) must implement an AML/CFT program by January 1, 2026. (For more information on this rule and requirements, please also visit our affiliated site: amlaudit.com) ITA Compliance, LLC is assisting advisers in two ways:

1

AML Program (DUE 1/1/2026)

ITA Compliance, LLC is collaborating with industry experts, including law firms, chief compliance officers, and experienced consultants, to make available a highly customizable AML policies and procedures manual. This manual can easily be customized by you, or you may wish to work with your consultant or counsel. For any firm hiring us to conduct the required AML testing, we are making this manual available to you for no charge.

2

AML Independent Testing

ITA Compliance, LLC will perform the independent testing required by FinCEN’s rule, which will be examined by the SEC. Our testing will evaluate:

Written AML/CFT Program

Customer Due Diligence (CDD)

Transaction and Activity Monitoring

FinCEN and Other Government Requests

Suspicious Activity Reporting (SAR)

Employee Training

Other books and records required by the rule.

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Other Projects

ITA Compliance, LLC has assisted investment advisers with a variety of other projects, such as audits of fee billing, email and social media reviews, and testing mandated by the SEC or state regulator as a result of enforcement actions.

For more information about our services, including pricing, please complete the online form located here or contact us directly at (617) 854-7500.