Preparation
- Prepare and submit ERA ADV filing to the SEC
- Review of private fund offering documents
- Collect employee information related to outside business activities and political contributions
Development of Policies and Procedures
- Review or create compliance manual and procedures
- Assess and assign risk
Maintenance
- Update disclosures, policies, and procedures based on business changes and regulatory issues
- Assist with creating and maintaining required books and records
Compliance Administration Process and Services Onboarding
- Dedicated onboarding team to integrate new clients into the team and our systems
- Ensure thorough understanding of the firm’s background, operations, client types, and investment strategies
- Review compliance-related documents and disclosures along with existing compliance program data
Assessment
- Perform an initial assessment of business practices, existing policies and procedures, disclosures, marketing materials, and filings
- Assess current compliance program
- Provide a gap analysis of regulatory requirements
- Make recommendations
Implementation
- Prioritize gap analysis findings
- Create, or update, compliance policies and procedures, Form ADV disclosures, including Parts 1, 2A, 2B, and Form CRS, and Appendix 1, as applicable
- Set up Code of Ethics reporting for adviser’s access persons
- Establish and maintain a compliance testing and reporting schedule
- Support the CCO with integrating the compliance program into firm operations
Management
- Support CCO with regulatory updates, integrate regulatory and firm changes into compliance program
- Maintain disclosure documents, compliance policies and procedures
- Assist with drafting and filing of ADV Parts 1, 2, CRS, and Appendix 1, as applicable
- Prepare other forms required to be filed with the SEC
Compliance Review Reports
- Prepare periodic documented reviews of compliance program
- Document Annual Review
- Provide testing results and collaborate with CCO to finalize and identify any action items
- Implement recommended changes
Marketing Review
- Assess marketing materials for content and disclosures
- Review materials against marketing rule requirements
- Assist with recordkeeping of approved materials
- Provide marketing compliance training
Email Review
- Assist with selection of a service provider to archive emails, if needed
- Periodically review emails and document findings
Employee Training
- Prepare and present compliance training at least annually and as needed
- New employee training on behalf of adviser
- Special topic or targeted new rule training
SEC Requests and Examination
- Coordinate preparations of materials requested by the SEC
- Prepare clients for the exam process
- Assist with remote and onsite routine examinations
Testing and General Compliance Support
- Integrate compliance policies and procedures into testing grid
- Assess and assign risk
- Establish testing process, data access, and schedule
- Perform and document testing on compliance policies and procedures, firm practices, and rule requirements
- Document compliance reviews, including Code of Ethics reviews
- Prepare compliance review reports for CCO review
- Bring potential issues to CCO and provide guidance and support to resolve and document as part of the adviser’s books and records
- Prepare materials for compliance-related meetings (e.g., best execution, proxy voting reviews, fair valuation, as applicable)
- Log material changes to compliance policies and disclosure documents
- Retain copies of compliance program-related documentation as part of the adviser’s required books and records
- Screen clients/investors against OFAC SDN list for basic AML review
Code of Ethics Testing and Monitoring
- Maintain list of access persons
- Prepare and circulate access person certifications and process review of completed certifications
- Coordinate access to personal trading data
- Ensure required recordkeeping is maintained for pre-clearance requests, personal trading data, restricted lists, political contributions, outside business activities, gifts, and entertainment reporting
- Test personal trading against adviser trading, restricted lists, and preclearance and other requirements in the adviser’s Code of Ethics, as applicable
- Prepare Code of Ethics compliance reports for review by the CCO
