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

Custody Concerns Continue

You timely filed your Form ADV within 90 days of fiscal year end, but did you properly answer all the questions related to custody? Not surprisingly, the Form remains confusing for many advisers, as does application of the Custody Rule itself. The SEC has issued guidance, letters to the industry, alerts and FAQs, but things … Continued

Blockchain Isn’t Hot Sauce

Guest post by Samson Williams, Partner – Axes & Eggs and Keynote Speaker – Ascendant CSS Spring 2019 Conference  I started telling people that blockchain isn’t hot sauce in mid-2017 to help explain why initial coin offerings (ICOs) were just the latest form of unregulated, online gambling. In November 2017, with Bitcoin nearing a high … Continued

The Importance of Effective ADV Disclosure: Staying Ahead of the Regulators

This ComplianceCast will discuss how firms can mitigate risk by having effective disclosure in their Form ADV Brochure. Our panelists will be CSS Ascendant Senior Consultant Ariana Monchick and Jessica Matelis, Partner at Foley & Lardner and former Senior Counsel at the SEC Division of Enforcement. They will discuss: Required disclosures The types of conflicts … Continued

Regulation Best Interest, Cybersecurity Top Concerns at IAA 2019 Compliance Conference

The Investment Adviser Association (IAA) represents the interests of investment advisers in Washington D.C., and the IAA Investment Adviser Compliance Conference 2019 was a forum for the discussion of future potential rulemaking. Cybersecurity and Fiduciary Rule considerations were headline topics, with custody and marketing right behind. The following is a summary of key issues discussed … Continued

The Challenges of Building a Global Compliance Program

Compliance programs face challenges in balancing global requirements with local exceptions while incorporating the fast pace of regulatory change, addressing critical business needs and obtaining the necessary resources necessary to manage the program. Trends and thinking on the subject were center stage at the recent CSS London event “Looking at the Year Ahead – Global … Continued

Coming to America – California Adopts GDPR-Like Privacy Regulation

After a number of firms struggled last year to get their marketing and information systems into compliance with the EU’s General Data Protection Regulation (GDPR), advisers to U.S. clients will soon be facing similar requirements on the home front.  On the heels of the Cambridge Analytica scandal, California enacted the California Consumer Privacy Act of … Continued

SEC and FINRA 2019 Examination Priorities

The SEC and FINRA have recently released their examination priorities for 2019. These releases provide insight into regulatory priorities and serve as guidance for a firm in evaluating its compliance program. We will discuss topics covered in these releases, including: Protecting retail investors Fees and expenses Disclosure Conflicts of interest Suitability Protecting senior investors Trading … Continued

SEC Reopened After 35-Day Government Shutdown

SEC Chairman Jay Clayton announced on Saturday, January 26 that with an agreement reached to end the government shutdown, the “Commission has resumed normal staffing levels and is returning to normal operations.” In total, about 94% of the commission’s approximately 4,400 employees had been furloughed during the 35-day shutdown, according to its operations plan. In a … 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.