CCOs for non "Trading" Private Fund Advisers
Our outsourced Chief Compliance Officer solution is designed to provide investment advisers with a Chief Compliance Officer, supported by a diversified compliance team with multiple skill sets, who will work to ensure the compliance function supports your fiduciary duty obligations. Members of our team have held executive level positions and possess diversified skill sets, including investment management, regulatory, operations, accounting, and audit.
With our outsourced CCO solution, clients can feel confident that they have the experienced support to help control and manage their regulatory obligations and mitigate their liability.
Using an outsourced CCO with access to the significant resources offered by our team can also be a prudent course of action because (1) an adviser may not have the necessary expertise or time with internal resources, and (2) we are independent.
Outsourced Chief Compliance Officer Service
The following are representative services:
- Designing a dynamic compliance program with adequate policies and procedures that are customized to your business. We focus on those areas of concern raised by the SEC, including conflicts of interest, allocation of investment opportunities, co-investments and expenses.
- Preparing and delivering firm-wide compliance training as expected by the SEC.
- Ongoing sampling reviews of marketing materials;
- Reviewing personal securities trading by an adviser’s access persons (checking for timely reporting of annual holdings and quarterly transaction reports, unusual trading patterns, pre-clearance approvals, etc.);
- Drafting compliance emails to be sent by the outsourced CCO or other officer regarding current regulatory initiatives, timely enforcement cases, or compliance reminders;
- Conducting quarterly electronic communications review of e-mails, instant messages and/or text communications sent or received through your electronic systems;
- Conducting annual employee compliance training;
- Conducting an annual compliance program review in accordance with Rule 206(4)-7 under the Advisers Act, which review takes into consideration changes to your advisory business as well as changes to the Advisers Act and other relevant federal and state securities laws;
- Reviewing of code of ethics logs, including gifts and entertainment, personal trading, outside business activities, etc.;
- Quarterly compliance “checkups”;
- SEC exam support; and
- Reviewing all trade allocations (to the extent there is overlapping investment periods) and any co-investment or side-by-side investing with a firm’s clients/investors and/or a firm’s affiliated entities.