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

OCIE Examined 15% of RIAs in 2017

In 2017, the SEC examined 2,114 investment advisers, approximately 15 percent of the 14,000+ registered investment advisers, the SEC confirmed in its Fiscal Year 2019 Congressional Budget Justification Annual Performance Plan. In the same report, the SEC said the staff will continue to improve its efforts of RIAs, noting that nearly 35 percent of all … Continued

Ascendant’s Adam DiPaolo Discusses Hypothetical & Model Performance Marketing Pitfalls

A Jan. 12 article in HFMCompliance titled “Best practice for hedge funds using hypothetical and model performance” outlines best practices for hedge fund managers when using hypothetical performance or model data in marketing efforts, and how managers relying on such data can avoid enforcement actions. Adam DiPaolo, Senior Consultant in Ascendant’s Private Funds group, is quoted in the … Continued

SEC’s Exam Priorities Offer Insight Into National Exam Program

On February 7, 2018, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued their 2018 Examination Priorities (see Ascendant’s summary here). In addition to defining their examination priorities for the year, the OCIE staff offered some insight into the National Exam Program.  Specifically, they defined the following five principles in executing their exam priorities: … Continued

SEC Updates: ICO Gatekeeper Standards, SEC/CFTC Swap Rules

SEC Chairman Jay Clayton had some stern advice for market professionals, especially gatekeepers, who he said need to act responsibly and hold themselves to high standards. Speaking via videoconference during Securities Regulation Institute’s recent annual conference, he said, “To be blunt, from what I have seen recently, particularly in the initial coin offering (“ICO”) space, they … Continued

Custody Toolkit

The complexity of the SEC’s Custody Rule is not to be underestimated. Custody issues remain among the most common deficiencies cited during SEC exams, and even firms with strong compliance programs have had challenges interpreting and applying the different rule elements, No-Action letters, FAQs and Investment Management Guidance Updates. Based on our experience in the … 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.