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

Takeaways and Tips Related to SEC Risk Alert on Regulation S-P

On April 16, 2019, the SEC released a Risk Alert providing a list of compliance issues related to Regulation S-P, the primary SEC rule regarding privacy notices and safeguard policies of investment advisers and broker-dealers. As with other risk alerts, these were deficiencies noted by OCIE in regulatory examinations. Though the deficiencies were fairly common … Continued

How to Be a Wildly Effective Compliance Officer

Being a Compliance Officer is no easy task. Administering a compliance program, implementing controls to help protect clients and the firm, and staying on top of new regulations is only part of the job. Compliance Officers are also expected to be flexible and pro-business. So how do you do it all? How can you be … Continued

Mitigating the Risk of Insider Trading

One of the biggest risks affecting investment advisers is the potential that material non-public information (“MNPI”) may be misused, leading to a charge of insider trading. Advisers should implement controls to mitigate these risks. Steven Stone of Morgan, Lewis & Bockius, LLP, Salvatore Cincinelli of the FBI and David Chaves of Tone at the Top … Continued

Compliance 2.0 – Being a Strategic Partner in Your Firm

Compliance as a profession continues to evolve. With Enron, Bernie Madoff and numerous other failures paving the way for rulemaking across industries and nations, the days of drawing a short straw, getting drafted into a compliance role and operating in isolation outside of the business are – or should be – ancient history. Since the … Continued

Big Data Part III: Preparing for the Future of Global Regulatory Governance

United States and European Union reporting requirements imposed on investment managers have exploded since the Global Financial Crisis and, with the imminent arrival of SFTR in Europe, it seems poised to expand again. The challenge of reporting trades, transactions and contracts in multiple jurisdictions requires firms to embrace technology as regulators continue to look to … Continued

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

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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.