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Regulatory Gap Analysis · 28 April 2026
FINRA · SEC · AML/BSA · Reg BI · BCP
Clearview Capital Management's compliance manual demonstrates a foundational compliance framework; however, the analysis identifies 18 significant gaps against applicable FINRA, SEC, AML/BSA, and Regulation Best Interest requirements. Seven findings present High risk exposure requiring immediate remediation before the firm's next regulatory examination. The firm demonstrates strength in investment policy documentation and Form ADV disclosures, but critical deficiencies exist in supervisory procedures, AML controls, and Reg BI implementation.
Immediately develop comprehensive Written Supervisory Procedures (WSPs) covering all business lines — this is the single highest-priority remediation
Establish a Customer Identification Program (CIP) with documented identity verification procedures for all new accounts
Implement a formal Regulation Best Interest compliance framework including a conflict-of-interest register and best interest documentation requirement for every recommendation
Develop, test, and document a Business Continuity Plan with recovery time objectives and emergency contact procedures
Create and distribute annual privacy notices to all clients to satisfy Regulation S-P requirements and implement a written information security program
FINRA Rule 3110(a)
Supervisory System
FINRA Rule 3110(b)
Written Supervisory Procedures (WSPs)
FINRA Rule 3310
AML Compliance Program
SEC Regulation S-P
Privacy of Consumer Financial Information
FinCEN 31 CFR 1020.220
Customer Identification Program (CIP)
SEC Reg BI — Rule 15l-1(a)(1)
Best Interest Obligation
SEC Regulation S-P Rule 30
Incident Response Plan
FINRA Rule 2111
Suitability
SEC Rule 204A-1
Code of Ethics
FinCEN 31 CFR 1010.610
Customer Due Diligence (CDD)
SEC Reg BI — Rule 15l-1(a)(2)(iii)
Conflict of Interest Obligation
FINRA Rule 4370
Business Continuity Plan
SEC Rule 206(4)-7
Annual Compliance Review
FinCEN 31 CFR 1020.320
Suspicious Activity Reports (SARs)
FINRA Rule 3110(c)
Internal Inspections
FINRA Rule 4511
Books and Records — General
SEC Rule 17a-3
Books and Records — Required Records
SEC Rule 17a-4
Books and Records — Retention
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Form ADV Part 2A provides comprehensive disclosure of services, fees, and conflicts of interest
Documented investment policy statement with clear asset allocation guidelines per client risk profile
Annual compliance training calendar established with attendance tracking
Client onboarding paperwork includes a detailed risk tolerance questionnaire
Segregation of duties between portfolio management and operations functions is documented
Human review required
Regis AI provides structured compliance risk information for review. It does not provide legal advice or make final compliance decisions. Escalate high-risk matters to qualified legal, compliance, HR, or governance professionals.
Prepared by Regis · High-risk findings should be escalated before further action is taken.