Outsourced Compliance & Business Development Consulting
With Broker Dealers and Registered Investment Advisers
compliance Disciplines
Service Areas
Bay Harbor provides consultative services & assistance to various firm’s CCO and GC’s with respective compliance matters as well as high-level long-term business planning development. Additionally, Bay Harbor provides a gateway by which such firms may retain the analysis of securities issues by an AMLAW 100 law firm on a per-project basis.
Services for Broker Dealers
Bay Harbor Advisors LLC provides compliance services to BDs including
- 3012/3130 Supervisory Systems Audits
- AML Audits
- Annual Compliance Meetings
- Books and records and filing systems
- Branch Audits
- Communication with the Public (Rule 2210)
- Conflicts of Interest
- CRD Maintenance (Forms U4, U5, BD, BR, etc)
- Cybersecurity
- Disaster Preparedness and Business Continuity
- Due Diligence: P/P, other products
- Electronic Storage Filings
- Email and social media surveillance
- FINRA and State regulators deficiency letters and responses
- Firm Element Continuing Education
- Gifts & Gratuities
- Insider Trading
- Outside Business Activities (OBAs)
- 3270 Analysis and WSPs
- Regulation Best Interest (BI) and Form CRS
- Registration Waivers
- State Registrations
- Supervision
- Written Supervisory Procedures
- General broker dealer compliance consulting
New & Continued Membership Applications for BDs
Bay Harbor Advisors LLC provides FINRA NMA and CMA Applications for broker dealers. Whether it is a new broker dealer or the development other business lines and personnel, Bay Harbor can assist you with your NMA/CMA application.
General Compliance Consulting Services
Bay Harbor Advisors LLC provides general compliance services including:
- General rule intepretation
- Guidance and best practices
- Development and implementation of supervisory procedures
- Preparation for regulatory review, inspections and inquiries
- Assistance with monthly, quarterly and annual filings
- Assistance with compliance matters that may arise during the course of business
- Updates on new or amended rules
- Research and answers to specific investment adviser compliance and registration questions
Services for Registered Investment Advisers
Bay Harbor Advisors LLC provides registered investment advisory compliance services for SEC and state Registered Investment Advisers including:
- Registered Entitlement Forms – to become a SEC or state RIA
- Form ADV
- Form ADV 3 (CRS)
- Form U4
- Written Compliance Policies and Procedures manual and Code of Ethics
- Notice filings
- Compliance Program Development and Monitoring
SEC Rule 206(4)-7 Testing – required annual on-site testing of RIA policies and procedures, including comprehensive review of:
- Advisory contracts
- Advisory fee arrangements
- Advisor transition
- Advertising and marketing materials
- Anti-money laundering procedures
- Annual compliance meetings
- Annual Review per 206(4)(7)
- Best execution
- Books and records and filing systems
- Code of ethics
- Compliance and procedures manual
- Conflicts of interest
- Disaster recovery and business continuity
- Electronic storage per CTFC-17, CRF-1-31
- Fee billing
- Form ADV
- Gifts & entertainment
- Outside Business Activities (OBAs)
- Insider trading policy
- Investment guidelines
- Pay to Play
- Performance materials
- Previous 206(4)(7) testing results and recommendations
- Risk management
- SEC or state deficiency letters and responses
- Supervision
- Trade allocation
- Trading practicies
- Valuation
The People behind the scene
Meet our team
Jeffrey Tooke
Managing Partner
Mr. Tooke came to financial services following a career in government and non-profit management. He has worked in local, county and state government in New York State over the past 15 years. Mr. Tooke has served most notably as chief of staff for the 57th NYS Senate District and as chief of staff in the Buffalo City Comptroller’s office, a $2.5M department with divisions of Accounting, Auditing and Cash Management. Whether in government or non-profit management, Mr. Tooke’s management focus has centered on strategic operations, public relations and staff supervision.
Over the past ten years, Mr. Tooke has served formally as Investment Adviser Chief Compliance Officer for a couple RIA firms and served as Chief Operations Officer for a broker dealer. Mr. Tooke serves presently as Chief Compliance Officer – Insurance for Four Points Capital Partners LLC in addition to serving in various roles with consulting client firms of Bay Harbor Advisors.
Mr. Tooke received his B.A. in Philosophy from Wadhams Hall Seminary-College in Ogdensburg, NY and his M.Ed. in School Counseling from the State University of New York at Buffalo.
Professional Credentials:
- Registered Representative (Series 7)
- General Securities Principal (Series 24)
- Registered Investment Banking Representative (Series 79)
- Registered Operations Professional (Series 99)
- Investment Advisory Uniform Combined State Law (Series 66)
- Insurance: Life, Accident, Health, Variable Life/Variable Annuities
Check out the background of this investment professional on FINRA’S Brokercheck: https://brokercheck.finra.org/individual/summary/5621579
Robert Barreca
Managing Partner
Mr. Barreca has over 15 years of experience in the capacity of Chief Compliance Officer and Branch Manager at several FINRA registered Broker Dealers. He presently serves as Chief Compliance Officer – Investment Banking at Four Points Capital Partners LLC in addition to serving in various roles with consulting client firms of Bay Harbor Advisors
Mr. Barreca’s focus is leading the firm’s compliance program and ensuring the firms compliance with all state and federal securities laws. He is experienced in assisting Investment Bankers with transactions including contractual and deal structuring issues. He also has extensive experience in business development and planning in the securities industry. He graduated with honors from The State University New York at Buffalo. Robert is active in The State University New York Buffalo School of Management’s alumni organization and is a recipient the Intern Supervisor of the Year Award for his volunteer mentoring work.
Professional Credentials:
- Registered Representative (Series 7)
- General Securities Principal (Series 24)
- Registered Options Principal (Series 4)
- Registered Municipal Securities Principal (Series 53)
- Registered Investment Banking Representative (Series 79)
- Registered Operations Professional (Series 99)
Check out the background of this investment professional here on FINRA Brokercheck https://brokercheck.finra.org/individual/summary/2490354
Let’s Talk
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We’re here to answer your questions and listen to your suggestions.
Bay Harbor Advisors LLC
2 Union Place
Buffalo, NY 14213
(716)912-8557