Free up internal resources and provide your investment adviser with a customized compliance solution.
Simon Compliance helps investment advisers navigate the compliance landscape by providing a compressive range of proactive compliance services and rate plans for firms of all sizes and needs.
For new investment advisory firms, we work to complete the necessary steps towards registration, from completing your Form ADV to creating a program that will foster a culture of compliance.
For established firms, we provide a comprehensive list of services to aid with ongoing compliance management.
We start with an independent compliance assessment, reviewing your current compliance manual and related policies and procedures and determining whether they adequately reflect your operations and are current with the law. We also evaluate your compliance operations to assist with implementing a more robust forensically tested program.
We partner with registered and unregistered investment advisers, hedge funds, private equity funds, real estate funds and venture capital funds. To implement and maintain a culture of compliance, we educate your CCO and employees and keep you up to date with regulatory deadlines, changes and developments.
From updates to reviews, we help firms focus on running their business while we help manage the compliance.
Registration and Compliance Program Build Out
- Create compliance manual, code of ethics, disaster recovery policy, cybersecurity policy, pay to play policy, valuation policy, anti-money laundering policy and others, as required
- Assistance with IARD Entitlement Package
- Create and file ADV Parts 1 and 2
- Review and coordinate with counsel regarding offering and subscription documents, as well as other legal issues
- Review and comment on marketing materials
- Review of website
- Create procedures for maintaining books and records
- Create a compliance calendar
- Create a log list and other systems to track ongoing compliance
- Provide training session about compliance program and/or particular areas of interest
- Provide resource for CCO, along with additional members of the firm, regarding compliance program and areas of interest
- Availability for phone calls and emails
- Assistance with third party vendor selection and onboarding
- Participation in third-party due diligence phone calls
- Assist with creating a forensic testing program
Ongoing Compliance Maintenance
- Annual and as needed revisions of Form ADV Parts 1 and 2
- Annual filings of Form PF
- As needed revision of compliance manual, along with related policies and procedures
- Review of marketing materials
- Annual training for all employees about the compliance program and areas of interest
- Assistance with annual supervised persons certifications
- Monthly/quarterly/annual reminders of compliance requirements
- Rule 206(4)-7 required annual review
- Provide resource for CCO regarding compliance program and areas of interest
- Advise on new compliance related releases, cases, and regulations including custody rules, FATCA, AIFMD, etc.
- Educational events held at Simon Compliance
- Mock audits
- As needed phone calls and emails
Ongoing and Additional Services
- Blue Sky filings (federal and state)
- Form D filings
- Assistance with anti-money laundering reviews and certifications
- Assistance with personal trading reviews
- Assistance with email reviews
- Assistance with SEC preparation and examination