SEC Enforcement Proceedings Consultant

Pursuant to enforcement proceedings by the SEC, Ascendant has been retained by many companies as their “independent compliance consultant.” This role has included:

    • Conducting a comprehensive “distribution-in-guise” review of the supervisory, compliance, and other policies and procedures designed to prevent and detect the improper use of fund assets to pay for distribution-related services;
    • Reviewing a company’s policies and procedures, making recommendations where the procedures were inadequate, and reviewing the firm’s implementation of recommended required or mandated procedures to address violations identified in the proceedings. Ascendant has been retained on separate matters related to insider trading, best execution and performance advertising.
    • Drafting additional compliance policies and procedures to reflect the adviser’s specific business model
    • Providing required or mandated recommendations, and assistance to demonstrate that the adviser had a reasonably designed and effective compliance program
    • Reviewing custody arrangements and verification of assets
    • Providing recommended required or mandated enhancements to the adviser’s operational policies and procedures and compliance program
    • Addressing SEC enforcement against an investment adviser to a registered mutual fund company
    • Making recommendations to remediate other issues cited by the SEC

Ascendant also served as a team member in the SEC-mandated oversight review of the American Stock Exchange.

Whatever your needs, Ascendant will work with you to make compliance a source of strength.

Please call 1-860-435-2255 for more information.

Contact Us

Latest Content

Advertising Issues: SEC and GIPS Performance in the Private Fund Space

Over a year ago, OCIE released the Risk Alert, “The Most Frequent Advertising Rule Compliance Issues Identified in OCIE Examinations of Investment Advisers.” While the alert highlighted several areas where performance advertising is involved, our recent CSS/Ascendant conference panelists in a session entitled “Best Practices for SEC and GIPS Performance in the Private Fund Space” … Continued

Placing Ethics and Compliance in the Foreground of Business Decision-Making

Thinking about how to make ethics and compliance part of a business’s decision-making can prove to be challenging. By nature, compliance professionals are often results-oriented, focusing on a binary end-result; either you are in compliance, or you are not. That focus is important, but emphasizing process is also vital, John Walsh, Partner at Eversheds Sutherland … Continued

What Am I Looking At? Making Sense of Your Cyber Testing Reports

It’s no surprise that Compliance and IT do not speak the same language. Compliance staff often speak in terms of regulations and policies, whereas bits and bytes are the language of IT staff. This distinction is clear when it comes to cybersecurity risk management, as the compliance and IT audiences are looking for different takeaways … Continued

Mailing List

Subscribe to the Ascendant Compliance email list for the latest compliance resources, conferences, ComplianceCasts™, and more.

Loading form...

Contact Us

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.