SEC Registration of Investment Advisers

Taylor & Gray efficiently and effectively guides Investment Advisers – Registered Investment Advisers (RIA) and Exempt Reporting Advisers (ERA) – through the SEC registration process. We collaborate with our clients to develop, implement and administer ongoing regulatory support through the adoption of written policies and procedures, designation of a knowledgeable Chief Compliance Officer and execution of annual review programs.

FINRA Broker-Dealer Registration

Taylor & Gray offers resources and expertise to enable broker-dealers to navigate through the exacting New Membership Application (NMA) process. We collaborate with our clients to file data in a timely manner while ensuring prompt responses to FINRA and interview preparedness.

NFA Registration

Taylor & Gray will lead or assist with Introducing Broker (IB), Commodity Pool Operator (CPO) and Commodity Trading Advisor (CTA) registration with the CFTC/NFA, granted only after a thorough background investigation to determine fitness standards set forth in the Commodity Exchange Act (CEA).

Compliance and Oversight for SEC-Registered Advisers

Our clients can confidently outsource their Chief Compliance Officer (CCO) function, their Compliance Support function, or both. Our services are thoughtfully and economically customized for each of our clients.

Compliance and Oversight for FINRA- & NFA-Registered Broker-Dealers

We provide Broker-Dealers with Regulatory Compliance guidance from time of membership application through growth stages by diligently developing internal policies and procedures to mitigate risk and maximize business opportunities.

Outsourced CCO Role

Taylor & Gray’s seasoned experts can be engaged, on an outsourced basis, to perform the Chief Compliance role and duties, including comprehensive creation, implementation and administration of our clients’ Compliance programs and reviews. As our clients grow, the outsourced CCO can train permanent and support staff. Our clients have found that outsourcing parts or the entirety of the CCO role can be financially and strategically advantageous.

Annual Compliance Program Review

Taylor & Gray will develop, implement and maintain reviews of our clients' business operations and compliance programs in relation to current and anticipated rules and regulations, including assessment of proper workflows and compliance controls. We will assist with regulatory inquiries and/or issues, and will interacting with regulators on our clients' behalf.

AML Independent Testing

We review and implement written AML policy and procedures. We review and independently test the effectivenss of our clients' AML program as it relates to compliance with the USA Patriot Act, the Bank Secrecy Act (BSA) and FINRA Rule 3310, as applicable. Our AML Testing Report and recommendations are provided upon completion of testing and evaluation.

The financial requirements mandated by FINRA include retention of a licensed professional to oversee the books and records, in addition to ensuring compliance with net capital rules. Taylor & Gray has the expertise and resources to supervise and/or manage financial reporting and accounting services functions, in addition to providing outsourced CFO and CCO services for a variety of financial institutions, including Broker-Dealers, Investment Banks, Investment Advisory firms, Commercial Banking, Private Funds and Early-Stage/Development Start-Ups.

Outsourced Accounting & Bookkeeping Services

Taylor & Gray will perform all back office accounting and bookkeeping services. These activities may be performed at a cadence that best suits our clients – on a weekly, semi-monthly or monthly basis. Our experienced team can be engaged to:

• set-up and support accounting for basic bookkeeping

• balance and reconcile ledgers as needed

• prepare and analyze GAAP and/or regulatory financial statements

• collaborate on and manage financial analysis, modeling valuations, budgeting, and forecasts

FinOp Services for Broker-Dealers

Our team will support and/or lead all financial duties corresponding with FinOp responsibilities and obligations at levels desired by our customers as follows:

• maintenance / oversight of the regulatory books and records, including preparation of regulatory reporting

• Financial and Operational Combined Uniform Single (FOCUS) Report filing, monthly or quarterly

• maintenance / oversight of member duties related to Net Capital calculations and other financial compliance requirements

• prepare or file Supplemental Statement of Income (SSOI), Securities Investor Protection Corporation (“SIPC”) Report and Assessment Report

Outsourced CFO Role

The team at Taylor & Gray can be engaged to perform Chief Financial Officer or Controller duties as well as business operations at levels stipulated by our clients. These services include a variety of practices and areas including start-up management, payroll, strategic planning/business development, budgeting, cost inefficiencies, contract negotiation, banking relationship management, risk management and tax advisory.

Independent Annual Audit Support

The experts at Taylor & Gray keenly collaborate with outside auditors and/or regulators as warranted for the annual audit and for audit exams. As requested, we can serve as our clients’ Appointed Representative and will respond unhesitatingly to all FINRA requests on their behalf.

Ancillary Services

Taylor & Gray will consult on, oversight and manage selected accounting, bookkeeping and financial reporting activities outside the scope of specific FINRA mandates and responsibilities including internal controls review, process framework and reporting, bankruptcy, liquidation and liability management, statutory dissolution, acquisitions support and investor due diligence and communications.

SEC / FINRA / NFA Examination Support, including Mock Exams

The Taylor & Gray approach and philosophy is based on being prepared and pro-active. In that spirit, we will conduct mock exams and rehearsals on a periodic basis by evaluating the initial document request list, performing in-person interviews and assessing internal systems and controls. At the conclusion of our process, we provide our recommendations and roadmap to your senior management team.

Risk Management

At Taylor & Gray, we strongly recommend proactive steps, where possible, to identify and manage areas of risk, and to enhance. If necessary, we develop and implement policies and procedures that address and manage these risks effectively. We will evaluate any aspects of your business that are subject to regulatory compliance, including but not limited to:

• Corporate Books and Records
• Customer Complaints and Arbitration Matters
• Associated Persons' and Representatives' Files
• Advertising and Marketing Materials
• Written Policies and Procedures Manual
• Firm Registration Records
• Client Disclosure Documents and Privacy Notices
• Anti-Money Laundering Program
• Business Continuity Plan
• Client Contracts and Account Files
• Supervisory Compliance Controls

Legal Entity Formation

• State Entity Formation
• New York State Foreign Entity Authority
• State Agent Filings
• IRS Tax ID Acquisition
• Corporate Formation Contractual Agreements

Virtual Currency Company Set-Up

• Application Filing with New York State Department of Financial Services for License to Engage in Virtual Currency Business Activity

Facilitation of Broker-Dealer Purchases and Sales

• Identification of Potential Targets
• Provision of Contracts and Letters of Intent
• Execution of FINRA Change of Control/Continuing Membership Applications