CCO Supporter Program
Our CCO Supporter program is an ongoing service that provides registered investment advisers and investment companies with continuous support in meeting their regulatory requirements. This program is designed to relieve our clients of the burdens of building and maintaining comprehensive compliance programs.
Our CCO Supporter program includes the following services:
- Initial diagnostic review of critical operations;
- Development of required and recommended policies, procedures and controls;
- Ongoing maintenance and submission of Form ADV and Section 13 Filings;
- Periodic compliance “check-ups,” including interviews with key personnel and testing of select compliance requirements (including best execution);
- Quarterly review of Code of Ethics reporting;
- Annual reviews of policies, procedures, and controls as required by Rule 206(4)-7 of the Advisers Act (including required documentation);
- “As-needed” updates of policies and procedures for critical regulatory developments;
- Ongoing reviews of marketing materials and performance composites;
- SEC examination management and support;
- Initial compliance training and annual training updates for portfolio management, trading and marketing employees; and
- Continuous “on-call” compliance support.
SEC Examination Management
As part of the CCO Supporter program, we provide ongoing support during SEC examinations.We assist our clients in understanding SEC requests and how best to provide materials and answers in an effective and expeditious manner.We also work with clients to respond to SEC comments and in developing appropriate action plans to correct any identified deficiencies.