Our ComplianceEvaluator projects are designed for established managers looking for a comprehensive compliance infrastructure review. This review can be done for SEC-registered managers as it relates to their obligations under the Investment Advisers Act of 1940 and other applicable regulations. This can also be a helpful review for managers that are not registered with the SEC but want to see how their infrastructure measures up against SEC requirements and other best practices.

The project team will perform a critical review of your internal compliance policies, procedures and existing business practices and provide feedback on our findings along with practical recommendations. Part of our feedback will include suggestions on how to simplify and streamline your procedures.

The scope of a ComplianceEvaluator project will be determined in collaboration with each client, but may include:

• Review of procedures and actual practices related to:
  • Record-keeping
  • Form ADV disclosure, delivery and updates
  • Code of ethics / personal securities trading
  • Annual compliance review
  • Review of fiduciary obligations
  • Insider trading
  • Money movement controls
  • Proxy voting
  • General employee responsibilities
  • Soft dollar usage
  • Privacy policies
  • Aggregation/allocation practices
  • Email retention and review
  • Best execution review process
  • Marketing materials
  • Public website use and Reg D issues
• Review of various disclosure documents for consistency among such documents and with actual business operations
• Review of hedge fund specific issues, such as:
  • Investor eligibility
  • ERISA calculations
  • 3(c)(1) beneficial owner counting
  • AML procedures, etc.
  • Blue sky procedures
• In addition, the project team will help you:
  • Modify procedures where there may be deficiencies
  • Revise, modify and/or expand your written compliance procedures if needed
  • Develop a complete written checklist of audit prep requirements
  • Develop a detailed compliance calendar that is unique to your business
  • Develop and implement a compliance training program for your employees

<< Project-Based Consulting Services