Ascendant Compliance Management offers an array of compliance services to support open and closed-end investment companies. We partner with investment companies and their sponsors to provide the assistance required to meet regulatory obligations under the Investment Company Act of 1940, as amended, and other federal securities laws. Ascendant’s services are tailored to your needs and include:

  • Assessing an investment company’s risks
  • Developing a compliance calendar for the investment company
  • Conducting compliance program reviews pursuant to Rule 38a-1
  • Developing due diligence programs and performing assessments of an investment company’s services providers, including investment advisers, sub-advisers, fund administrators, distributors and transfer agents
  • Reviewing and drafting policies and procedures
  • Conducting mock SEC exams
  • Evaluating the effectiveness of business continuity and cybersecurity programs
  • Delivering customized training programs

Ascendant also provides assistance with conducting focused reviews on specific topics, such as:

  • Evaluating compliance with portfolio guidelines and trading policies
  • Reviewing fund distribution practices, including:
    • Load structures
    • Rule 12b-1 plans
    • Selling and servicing agreements
    • Sub-TA and other recordkeeping arrangements
    • SSAE16 and FICCA report analysis
    • Fund advertising
  • Examining fees and expenses vis-à-vis disclosure documents and policies
  • Evaluating the effectiveness of the investment company’s Code of Ethics and conflicts of interest policies
  • Serving as independent consultant in connection with SEC remediation plans
  • Reviewing fund valuation policies and procedures

Using our proprietary Ascendant Compliance Manager, we can help fund sponsors:

  • Catalog policies and procedures
  • Develop a risk assessment “heat map” showing the highest risk activities and controls to mitigate
  • Review fund transactions for affiliated trades, window dressing and portfolio pumping

Please contact us for information regarding outsourced CCO support for Investment Companies.