Hedge Fund Programmes
For US-based hedge funds we provide high touch registration services with both the Securities Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”).
Our registration programmes work in parallel with your Chief Compliance Officer in order to implement a tailored compliance manual that includes compliance programme policy and procedures design and administration and that is consistent with the Investment Advisers Act of 1940 (the “Adviser’s Act”). Our registration programmes include working closely with you to complete all parts of your Form ADV registration including Form ADV Part 1A, Form ADV Part 2A (the “Brochure”) and Form CRS (your client relationship summary) where applicable. We will file your initial Form D in addition to supporting your ongoing state Blue Sky filings where necessary.
Each private fund compliance programme is designed to address the unique compliance risk considerations of your hedge fund, private equity, or venture capital advisory business. Such risks include evaluation and adequacy of your ADV Part 2A Brochure disclosures, AML procedures, marketing and advertising practices, compliance filing procedures, Code of Ethics implementation, and overall adherence to fiduciary obligations. We work closely with each investment adviser to administer policies and procedures designed to mitigate your compliance risk.
If your business is not required to register with the SEC due to a relevant exemption, we will work with you to file Form ADV ERA as an exempt reporting adviser and tailor a compliance programme consistent with your exemption status that meets all relevant aspects of the Adviser’s Act.