SDDco guides investment advisors through the intricacies and requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act, called “one of the most complex pieces of legislation ever written”. SDDco also prepares SEC and state registration filings, and provides compliance services to investment advisors and private fund managers.
Per the Investment Advisors Act (Rule 206(4)-7, SDDco assists registered investment advisers (RIAs) through the development of a customized compliance program, the adoption of written policies and procedures drafted to prevent violations, the designation of a knowledgeable Chief Compliance Officer (CCO), and the execution of annual program reviews.
Investment Advisor Registration
SDDco leads advisers through fulfillment of their SEC filing requirements as follows:
- Creating and filing Form ADV Parts 1 and 2 and supporting documents
- Developing your customized Written Supervisory Procedures
- Drafting your Code of Ethics, BCP and Insider Trading Policy
- Developing Solicitor’s Agreements and Disclosure Statements
- Reviewing planned marketing materials
- Licensing appropriate personnel
RIA Compliance Support
SDDco provides year-round assistance to RIAs, on a retainer basis, to facilitate the regulatory compliance. When your employee is the named CCO, an SDDco consultant can be engaged to perform the following functions:
Policies and Procedures:
Update the compliance manual to reflect changes in regulations in your advisor business, draft all policies and work with management to implement revisions;
Create a detailed calendar to ensure timely completion of activities by relevant parties;
Conduct the annual review of the effectiveness of the policies and procedures;
Advice and Support:
Provide unlimited real-time advice and guidance to management and staff;
Prepare/file any routine ADV amendments and state notice filings;
Prepare and file any Section 13 filings;
Conduct quarterly meetings of an internal compliance committee;
Collaborate to conduct an annual risk assessment including an assessment of the likelihood and impact of given business risks such as infrastructure, human resources, portfolio management, performance, expenses and service providers;
Review all marketing materials for SEC and FINRA compliance.
Outsourced CCO Service
An SDDco consultant can perform with proper knowledge and authority as CCO to administer your compliance program. Working closely with management and staff, your SDDco CCO will plan, implement and maintain your compliance program. If engaged for CCO Service, SDDco would provide all the support service detailed above plus the following:
Chief Compliance Officer
Administer your policies and procedures, report to management and staff, provide the annual written compliance report, and handle all CCO matters required;
Ensure that all relevant personnel and service providers receive and understand the compliance policies and procedures and obtain respective certifications;
Code of Ethics and Insider Trading
Manage all Code of Ethics and Insider Trading activities including per-clearance and reviews of trading;
Insure timely delivery of all applicable privacy notices to clients;
Provide training on topics relevant to the compliance program;
Respond to regulatory exams conducted by the SEC or FINRA, including assembling materials and interfacing with the exam staff;
Provide service on any other compliance-related project request.
Benefits to You
For two decades, our seasoned experts have worked with major asset management firms and service providers to the asset management industry. This breadth of experience enables us to bring a “best practices” perspective to the compliance support we provide. SDDco can establish a service model that best fits your needs and maintain your institutional compliance history through regulatory, business and personnel changes. We are an independent entity imparting fund sponsors, boards of trustees and investors with the confidence that an experienced, independent firm is supporting their funds’ full compliance with regulatory requirements.