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.