Our semi-annual compliance review services are ideal for managers that are looking for periodic tests of their compliance infrastructure and continuing compliance and regulatory support. Through a semi-annual series of on-site visits and off-site work, our team will perform a review of fund-level and adviser-level compliance issues. We will also assist you with targeted compliance responsibilities such as administering your annual compliance review and conducting employee training sessions.

The scope of the engagement 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
  • 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
  • Solicitation arrangements
• Review of various disclosure documents for consistency among such documents and with actual business operations
• Modify procedures where there may be deficiencies
• Revise and modify your compliance manual as needed
• Creation and update of detailed compliance calendar
• Assistance in administering an annual compliance review
• Conduct compliance training meeting for employees
• Selective review of hedge fund specific issues, such as:
  • Investor eligibility
  • ERISA calculations
  • 3(c)(1) beneficial owner counting
  • AML procedures, etc.
  • Blue sky procedures
• Assistance with annually updating Form ADV (as applicable)
• Serve as a compliance and regulatory resource for the firm

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