Investment Company Services

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.


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Latest Content

Firms Encouraged Not to Overlook Oct. 1 Books and Records Changes

While changes to Form ADV on October 1, 2017 have been well-publicized, we encourage firms not to overlook the other changes to Books and Records requirements put forth in the SEC’s final rule release, effective October 1, 2017. The changes to the Rule relate to the retention of documents regarding the calculation of performance data. Rule … Continued

SEC Offers Regulatory Relief to Advisers Affected by Hurricanes

On September 28, 2017, the SEC provided regulatory relief to individuals and entities subject to the ’33 Act, ’34 Act and ’40 Act who were affected by Hurricanes Harvey, Irma or Maria. The relief came in the form of conditional exemptions from certain requirements. The hurricanes, which struck between August and September of 2017, devastated … Continued

SEC Discloses Cybersecurity Breach That May Have Led to Insider Trading

The determination of hackers to exploit existing cybersecurity vulnerabilities of government agencies and businesses shot to the forefront again last Wednesday, when SEC Chair Jay Clayton revealed that the commission’s EDGAR database had been hacked in 2016 through a software vulnerability in the test filing component of the system. According to Clayton, the breach was … Continued

Ethics: Building a More Ethical Workforce

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Ascendant’s Jason Morton to Speak on RegTech at Strata Data Conference

Alongside technology experts from American Express, Credit Suisse and CIBC, Ascendant’s Jason Morton will speak on developments in regulatory technology at the ‘Fintech Data Day’ at the annual Strata Data Conference on September 26, 2017 in New York. The Strata Data Conference is an annual conference for technology and business professionals who are seeking innovative … Continued

Hurricane Season: How Does your BCM Program Stack Up?

As Hurricane Harvey touches down on U.S. soil and we hope for the safety of the millions in its path, we encourage all firms, even those outside Harvey’s path of flooding and damaging winds, to consider their BCM readiness for such an event. Business Continuity Plans are designed to ensure firms have conducted sufficient advance preparation so … Continued

Surprise, Surprise: SEC Conducting Unannounced Exams

The Boston Regional Office of the SEC has recently conducted roughly 20 unannounced visits to registered investment advisers in the region. This fact, confirmed during the recent meeting of the New England Broker-Dealer and Investment Adviser Association (NEBDIAA), is in keeping with the SEC’s renewed focus on a more robust examination program. While onsite, the … Continued

One Phish, Two Phish, Red Phish, Blue Phish: How to Detect and Mitigate Social Engineering and Ransomware Techniques

Ransomware attacks like WannaCry and NotPetya are increasing in both frequency and damage, routinely making headline news with their abilities to bring down networks of established companies. Yet these cyberattacks typically start by compromising the weakest point in your security chain – people – through simple or complex phishing techniques before spreading to other parts … Continued

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Ascendant works together with clients to identify and assess critical needs through customized plans. If you need assistance with compliance functions, regulatory services, cybersecurity or technology tools, we’d love to speak with you.