Struggling to maintain and implement a policies and procedures manual that's specific to your RIA business? Get help here from our special guest author.
“Compliance is cool!” said no one ever.
Okay, that was a little harsh. I have a love/hate relationship with compliance. As someone who started my career in the wirehouse world as a client service associate, I’ve always felt held back by certain policies and procedures and I know I’m not alone in that feeling.
When I finally broke free from my corporate restraints and started working for a startup RIA, I felt so free. It took a while for me to realize that the feeling of freedom existed because we had no idea what we were doing, and our policies and procedures manual was nonexistent. As a firm, we were just trying to figure it all out and serve our clients the best way we knew how. Eventually, we got around to creating a policies and procedures manual and it was a painful experience.
My boss and I sat in our conference room once a week with some random documents we got from a Google search and tried to write our own manual. We had a giant Excel spreadsheet with topics, notes, and references. I felt so far out of my element and extremely uncomfortable with the process.
Several years later, when I eventually started my own consulting firm, I was excited at the prospect of not having to be registered as an investment adviser and not being subject to the same level of compliance I had been for a decade. I felt free again.
Shortly after I started my firm, I was approached by an individual who was starting his own RIA. He was an industry switcher, so he had a prospect list instead of an existing book of business. He had discovered some of my content in his research and wanted to hire me to help him with some of the startup tasks he was facing. My business was still new, and I wasn’t yet in the habit of turning down less-than-ideal sources of income. So I agreed to help.
One of the things he asked me to do was read his entire policies and procedures manual and provide him honest feedback. It was a standard template provided by his compliance firm, and it was over 100 pages long! I read the entire thing, compared it to his Form ADV, and came back to the table with tons of notes. We went back and forth for hours about the content and eventually provided a list of questions to the compliance consultant. While less than thrilled, the consultant addressed each item and made the changes to the document that we asked for. The turnaround time on the whole process was probably a week. I’m feeling some anxiety just thinking about it.
Needless to say, I added P&P manual review and revision to my mental “never again” list.
Fast forward to when I met Derek Witman, a product specialist at Joot. He approached me on LinkedIn and asked if we could chat about our respective businesses. I was happy to do so because I wanted to stay in my lane and focus on helping advisers transition books of business. I recognized that a HUGE part of that process is compliance, but I didn’t want to be the person consulting on that aspect. I wanted an expert in that field to weigh in so I could continue to do what I do best and never again get stuck reading 100 pages of policies and procedures.
So when Derek suggested I do a demo of the Joot platform, I happily agreed and I’m so glad I did. I’m not going to bore you with all the details, but I am going to show you the feature that changed my life.
It’s called the Policies Manager. It’s a tool that will auto-generate a policies and procedures manual for your firm based solely on the information in your Form ADV. No reading and manually redlining a 100-page document or Googling instructions and trying to piece together a file like a puzzle.
I can write about it, which I did for the rest of this article, or you can go test it out here for yourself.
All you have to do is enter your CRD number and the tool will access your Form ADV and email you a list of suggested policies and procedures that should be in your manual—personalized for your firm based on the information from your ADV.
And that’s just the free version of the tool. Something you can access right now. The paid version, which is just one of the many features Joot offers with their ongoing compliance support, is even cooler. Yeah, I said it. Compliance is cool. I’ve changed my tune.
That version produces a list you can use to create the manual.
You select the policies and procedures from the list that you want to include in your manual, and you click a button to generate the document.
A manual is auto-populated and a table of contents is provided. Each section has a hyperlink you can click on to take you directly to the contents of that section.
From there, you can read your policies and procedures. They’re written and formatted for you. By professionals. People that aren’t you. You don’t have to do anything. I cannot stress that point enough. It takes 5 minutes!
But that’s not all. You can click into the specific sections and edit them. Not just you. Your entire team. It’s sophisticated document-sharing technology that also keeps track of your document history. You can see who edited what and when they edited it. No more arguing over which version is the most recent version, where it’s saved, and who was the last to touch it.
You can also use the tech to request approvals. Any or all members of your team can open the document to review the changes and sign off with their approval. A report can then be generated showing all the activity. A comprehensive document that’s easily accessible and audit ready. And it can all be done in a matter of minutes without ever picking up a pen.
And that’s just one of the many documents you can use this tool to edit. Any requirement you can think of is going to be made easier using Joot’s tech. Plus, your compliance manual and all your documents are auto-synced with your compliance calendar for the year. Never miss a deadline again!
There’s not much more to say. If you’ve read this far, you understand the appeal of this technology to someone like me. Someone with years of flawed P&P manual creation experience. Someone who views compliance as a necessary nuisance. Any technology, or consulting firm in general, that can make an adviser’s job easier is a tool I’m going to educate my connections about.
If you’re considering a change in compliance firms, or you’re researching your options for an upcoming transition, reach out to my friend Derek Witman and see what Joot has to offer. No compliance firm is going to be a good fit for everyone. Due diligence is crucial. Make sure you understand the options you have available to you. If you want to learn a little more about Joot, you can visit their website here.