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

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On April 18, 2018, the SEC voted to propose several new rules and reforms related to fiduciary standards. The package intends to raise and clarify standards of conduct for broker-dealers and investment advisers, and to provide clarity regarding fees, conflicts and other material matters. It also aims to ensure that the standards can be understood … Continued

Insurance Considerations for Investment Advisers

How much coverage is enough? What types of insurance policies do you need? Whether you are starting an investment advisory practice, launching a new line of business, or reevaluating your existing risks, there are critical questions to ask to make sure you understand the various ways to protect your firm. Join us for a practical … Continued

Fifth Circuit Weighs In on DOL Fiduciary Rule

A panel of the U.S. Court of Appeals for the Fifth Circuit has vacated the Department of Labor’s Fiduciary Rule. In a 2-1 split, the Fifth Circuit’s decision overrules a Dallas District Court’s decision, which had previously upheld the rule. Unfortunately, the decision does little to settle the fate of the beleaguered rule. Although it … Continued

SEC Proposes Amending Investment Company Liquidity Disclosures in Forms N-PORT and N-1A

On March 14, 2018, the Securities and Exchange Commission (“SEC”) proposed amendments to the mutual fund liquidity-related disclosure requirements. Specifically, the proposal: Adds a new requirement to “briefly discuss the operation and effectiveness of the Fund’s liquidity risk management program during the most recently completed fiscal year” in the Fund’s Management Discussion of Fund Performance … Continued

Paradigm Shift in SEC Exams, Benefits of a Mock Exam

For investment advisers currently going through an SEC exam, the process likely bears little resemblance to exams of old. Call it the new normal, a paradigm shift, or simply the effects of the SEC having to do more with less, but anecdotal evidence among those now experiencing the exam process suggests some interesting new trends. … Continued

Why Should a Big Hedge Fund Use a Compliance Consultant?

If your firm isn’t already using an outside consultant, you may want to ask yourself “why not?” Oftentimes at hedge funds, compliance officers struggle to successfully fulfill the requirements of the job without an essential tool in their toolbox: the outside compliance consultant. Why? The primary reason is simple: resources. When your head is down … Continued

Custody – Get It Right: Just in Time for Your Annual Updating Amendment!

The SEC’s Custody Rule and its application to registered investment advisers is complicated and often misunderstood, and custody issues remain among the most common deficiencies cited during SEC exams. Download this important ComplianceCast to understand the key elements of the Custody Rule; identify available exceptions to certain requirements of the Custody Rule based on industry … Continued

SEC and FINRA 2018 Examination Priorities

The SEC and FINRA have recently released their examination priorities for 2018. 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 Disclosure Best execution Mutual fund selection Anti-money laundering Cryptocurrencies Technology and cybersecurity

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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.