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Investment Companies

The scope of what should be included in compliance programs is ever-expanding, but the resources are scarce. Among the challenges facing funds is the ability to maximize the compliance capabilities of limited resources while minimizing the impact to shareholders. This is the common resource gap that separates proactive compliance programs from those that may leave shareholders open to risk. SEC3 provides expert resources and support to fund Chief Compliance Officers and Boards to bridge the resource gap. We align our efforts with the CCO and share in the commitment to the shareholders.

SEC3 offers an extensive suite of customizable compliance services for Investment Companies, on either a one-time or recurring basis depending on your needs.

Examples of potential services include, but are not limited to:

  • Annual Compliance Reviews
  • Compliance Program Evaluation Assistance
  • Risk Assessment and Gap Analysis
  • Compliance Testing and Analysis
  • Mock SEC Examinations
  • AML Review
  • Compliance Training
  • Customized Compliance Services

Additional information about some of these services is outlined below.

Annual Compliance Review

The Compliance Rule requires each fund to review its policies and procedures, and the policies and procedures of the fund's service providers, at least annually, to determine their adequacy and the effectiveness of their implementation. In Annual Compliance Review services, SEC3 can assist Chief Compliance Officers in every phase of the annual review process, from formulating a strategic plan, to conducting thorough assessments and testing of all aspects of the compliance program, to planning for next year's review. SEC3's Annual Compliance Review allows funds to maximize available resources by fulfilling specific elements or the entire scope of the regulatory obligation. The Annual Compliance Review can conclude with a customizable, easy to read report and action plan.

Compliance Program Evaluation Assistance

Assessing the adequacy of an adviser's or service provider's compliance program is critical for a fund. With Compliance Program Evaluation Assistance, SEC3 can assist a fund's Chief Compliance Officer and Board in fulfilling their due diligence in assessing compliance programs. SEC3 can assist in the evaluation of the comprehensiveness and adequacy of a compliance program or the most recent annual review of a compliance program. Compliance Program Evaluation Assistance also extends to providing the Chief Compliance Officer or the Independent Directors with an independent, second opinion of an adviser's or fund's annual review approach, methodology, and follow-up measures.

Other customized services include:

  • Reviews of 15(c) Reports from Advisers
  • Sub-Adviser Due Diligence & Monitoring Review
  • Support Activities of the Chief Compliance Officer
  • Reviews of Service Provider Policies and Procedures
  • Custom Reviews and Analysis for Board of Directors/Trustees
  • Specialized Training to Board of Directors/Trustees

Newsletter

Get the latest compliance news and insights - delivered weekly. The SEC3 Communique covers all compliance topics. CCO3 focuses on CCO topics.
tip: check both to keep informed!

Communiques

FINRA’S Box of Chocolates

While we know you prefer a box of chocolates today instead of this industry update on compliance, this one is a gift and hence, will not add to your ever-growing... read more »

A Motivated Agency: The SEC Closing the Loop on the Edgar System Cyber Breach

You may recall after Clayton took the helm as Chairman at the SEC, the agency disclosed that it had its own cyber breach and the Edgar system was compromised. Today,... read more »

Examiners Take Reprieve with Gov’t Shut Down, But CCOs Must Carry On

These government shut downs don’t usually go on indefinitely. Before we blink an eye, examiners will be back on the beat. CCOs must stay vigilant. On December 20th the SEC’s Office... read more »

Pre-Dating & Back-Dating are Equally Risky

The SEC today suspended three accountants formerly of BDO USA LLP for improper professional conduct during its 2013 audit of AmTrust Financial Services Inc., an exchange-listed insurance company. According to the... read more »

Fiduciary Duty

On Friday, September 28, 2018 the SEC charged LendingClub Asset Management (LCA) and its former president Renaud Laplanche with fraud for improperly using fund money to benefit LendingClub Corporation (LendingClub),... read more »

Exciting Summer Project -- Dig Into Some Sand or Dig Into Your Firm's Best Ex Pr…

The Office of Compliance Inspections and Examinations (OCIE) issued a risk alert July 11 targeting investment advisers’ most common deficiencies with regard to their best execution obligations under the Investment... read more »

Events

Chief Compliance Officer Roundtable: Breakfast Briefing - November 8, 2018

When: November 8, 2018 Where: Blank Rome LLP | The Chrysler Building | 405 Lexington Avenue | New York, NY 10174 | 22nd Floor Boardroom | Phone: 212.885.5000 Schedule: 9:00-9:30am - Networking...

Dorsey PF 2018 Symposium

When: September 26, 2018 (8:30 am - 6 pm Where: Dorsey & Whitney LLP | 51 W. 52nd Street | New York, NY 10019 Directions > SEC3’s President, Janaya Moscony will join...

Chief Compliance Officer Roundtable: Breakfast Briefing - June 14, 2018

When: June 14, 2018 Where: Blank Rome LLP | The Chrysler Building | 405 Lexington Avenue | New York, NY 10174 | 22nd Floor Boardroom | Phone: 212.885.5000 Schedule: 9:00-9:30am - Networking...

Webinar: 2018 SEC Exam Priorities & Recent Exam Highlights

Don’t miss the opportunity to meet with us in person to discuss the topics that matter most to you. Tobin S. Cochran, Managing Member/President of Focus 1 Associates, LLC and...

Chief Compliance Officer Roundtable: Breakfast Briefing - February 7, 2018

When: February 7, 2018 Where: Blank Rome LLP | The Chrysler Building | 405 Lexington Avenue | New York, NY 10174 | 22nd Floor Boardroom | Phone: 212.885.5000 Schedule: 9:00-9:30am - Networking...

Upcoming Events - September & October 2017

Upcoming Events Don’t miss the opportunity to meet with us in person to discuss the topics that matter most to you. SEC3 is teaming up with industry experts in NYC to discuss...

May 23, 2017 - Webcast: WannaCry Ransomware: Were You Really Protected or Just L…

When: Tuesday, May 23rd, 2017 | Schedule: 12pm - 1pm EST Who: Paul Caiazzo, CEO and Co-Founder, TruShield Security Solutions Michael Brice, Founder, BW Cyber Services John Lukan, Managing Director, SEC Compliance Consultants, Inc. We...

June 14, 2017 - Compliance Breakfast Briefing

8:30-9:00am - Networking and Continental Breakfast 9:00-10:30am - Program Location: Willkie Farr & Gallagher LLP | 600 Travis Street | Suite 2310 | Houston, TX Barry Barbash from Willkie Farr & Gallagher LLP,...

June 13, 2017 - Compliance Breakfast Briefing

8:30-9:00am - Networking and Continental Breakfast 9:00-10:30am - Program Location: Haynes and Boone, LLP | 2323 Victory Avenue | Suite 700 | Dallas, TX 75219 Validated parking is available in the garage attached...

May 31, 2017 - Chicago

9:00-9:30 a.m - Networking and Continental Breakfast 9:30-11:00 a.m - Program Location: Baker & McKenzie LLP | 300 East Randolph Drive | Suite 5000 | Chicago, IL 60601 Kristin Gonzalez and Jerome Tomas...

May 17, 2017 (NYC WIMF)

This event is by invitation only. Please email info@seccc.com to learn more.

May 15, 2017 (NYC Chief Compliance Officer Roundtable)

9:00-9:30am - Networking and Continental Breakfast 9:30-11:00am - Program Location: Blank Rome LLP | The Chrysler Building | 405 Lexington Avenue | New York, NY 10174 | 22nd Floor Boardroom | Phone:...

Webcast: The Most Insidious Cybersecurity Threat Is Also The Least Understood

When: Tuesday, April 25th | Schedule: 12pm - 1pm EST Who: Paul Caiazzo, CEO and Co-Founder, TruShield Security Solutions Michael Brice, Founder, BW Cyber Services John Lukan, Managing Director, SEC Compliance Consultants, Inc. Ransomware, the...

CCO Liability (Part III): Managing Liability Webinar

In this webinar, panelists discuss indemnifications and insurance as potential remedies to address the direct financial risks to a CCO. Attendees will learn: What terms and conditions should Chief Compliance Officers be...

Webinar: CCO Liability (Part III): Managing Liability: Navigating Indemnities an…

When: Tuesday, February 21, 2017 Schedule: 11:00am ET / 10:00am CT / 9:00am MT / 8:00am PT / 7:00am AT Description of Webinar: The National Society of Compliance Professionals is pleased to host...