Adviser consulting

Practical compliance solutions for fund managers and investment advisers

As a registered investment adviser, you have compliance obligations – regardless of whether you’re exempt or must register with the SEC. And, while the obligations differ, it’s important to understand what’s required of you and when.

Relying on outside advisers for compliance related functions is a cost-effective alternative to hiring dedicated compliance resources or assigning the duties to current staff for established and emerging managers. By leveraging external advisers, you benefit from experts steeped in industry best practices and current compliance regulations.

Registration support

Depending on the nature and size of your business, you may need to register with the SEC, CFTC and/or the NFA. We evaluate your business and determines whether registration is required or whether applicable exemptions are available.

We follow a detailed roadmap for the registration process, ensuring an organized and efficient process. Concurrent with registration, we work with you to install the framework needed on day one of registration.

Ongoing support and advisory services

Regulators expect your firm to be fully compliant with their rules at all times – there are no compliance breaks. This means ensuring compliance policies and procedures are fully and accurately documented and tested. You must also keep up with your compliance program commitments, including training, attestations, testing and surveillance.

Because policies and procedures impact processes, workflow, resources and cost, we work with you prior to, during and after registration to develop solutions that fit your firm’s size, complexity and stage. We strive to minimize disruption and cost while achieving full compliance with regulatory requirements.

Ongoing support and advisory services include:

  • Rule 206(4)-7 annual reviews
  • compliance program reviews
  • risk assessments and regulatory gap analyses
  • portfolio management reviews
  • code of ethics/personal trading reviews
  • investment allocation and trading reviews
  • financial crime/anti-money laundering reviews
  • cybersecurity
  • specialized reviews and compliance assessments
  • annual and ongoing reviews of compliance arrangements, systems and controls
  • marketing and advertising review
  • mock regulatory audits, pre-enforcement and supervisory reviews
  • support with on-site regulator visits, examinations and enforcement investigations
  • regulatory and compliance training.

A practical approach to ongoing compliance

We know that for a compliance program to succeed it must be practical and sustainable. This is why we have developed a five-pillar compliance model to help private equity managers establish and adhere to solid compliance protocols.

Mock exam services

Deficiencies in a regulatory exam can negatively impact operational due diligence (ODD) reviews, and may result in reputational damage and/or a fine. Mock exams help identify areas of weakness for advisers ahead of an SEC examination. The goal of a mock exam is to minimize – or ideally eliminate – the number and severity of potential violations.

Mock exams also provide essential practice for effective and efficient interactions with the SEC. This includes locating and producing documentation, delivering information in the requisite format and polishing the interview skills of key individuals.

SEC mock exams