INVESTMENT ADVISER SERVICES

Compliance Solutions

C³ Solution®

On-Going Compliance Support

1. Annual Mock SEC Inspection and Compliance Program Review
2. Review of Policies, Procedures, Agreements, and Compliance Documents
3. Access to ACA’s Library of Compliance Documents
4. On-Going Marketing and Advertising Review
5. Initial and On-Going Form ADV Review
6. Customized Compliance Manual (initially prepared or amended subsequent to ACA’s completion of its annual mock SEC inspection and compliance program review)
7. Unlimited Customized Telephone Consulting
8. IARD Administration
9. SEC Filing Support, including Form 13F and Schedule 13G (if/when applicable)

SEC Inspection Support

10. SEC Inspection Response Program (on-site compliance assistance during an SEC examination for a maximum of five business days per contract year with unlimited off-site assistance)
11. Review and Preparation of Documents Requested During an SEC Inspection
12. Deficiency Letter Response Writing
13. Off-Site Assistance with Informal SEC (and State) Regulatory and Compliance Inquiries

Compliance Education and Training

14. Annual Employee Compliance Training
15. Subscription to ACA Insight (weekly compliance newsletter)
16. Access to ACA Compliance Webcasts
17. Periodic Email Compliance Alerts

Hedge Fund Inspections

ACA provides hedge fund managers with peace of mind by conducting inspections focusing on high risk areas that could subject the adviser to liability. Specifically, our inspections include a detailed review of the following high risk areas:

• Adherence to the investment objectives described in offering documents
• Valuation of Assets
• Analysis of financial statements to ensure that payments are made in accordance with disclosures provided to investors
• Review of all correspondence with investors and any marketing materials used to solicit investors
• Assessment of suitability requirements and compliance with such mandates
• Compliance with registration exemptions under the Securities Act of 1933 (including Regulation D), the Investment Advisers Act of 1940, and the Investment Company Act of 1940

To complete this detailed review, ACA closely scrutinizes the following documents:

• Operating Agreements
• Private Placement Memoranda and Other Offering Materials
• Subscription Agreements (including qualifying questionnaires)
• Capital Account Worksheets
• Custodial Statements
• Financial Statements
• Correspondence Between the Adviser and Investors (such as quarterly letters)
• Marketing Materials Designed to Solicit Additional Investors or Maintain Current Investors
• Regulatory filings, including Form D, filed with the SEC

To learn more about hedge funds, click here.

Investment Company Assurance Services

Solutions designed to successfully achieve and maintain the integrity, reputation, and independence that investors and shareholders demand of today’s leading investment management firms.

• Mock SEC Inspection
• SEC Inspection Response Program
• Deficiency Letter Response Writing
• Periodic and Systematic Best Execution Review
• Investigation of Complaints
• Risk Management Evaluation

Compliance Cornerstone™

This product provides ACA's business partners with a wealth of bundled services and benefits including a customized review.

• Unlimited Customized Telephone Consulting
• Access to ACA’s Library of Compliance Documents
• ACA Insight Subscription (weekly compliance newsletter)
• Periodic Email Compliance Alerts
• IARD Administration
• An initial Limited Scope Off-Site Compliance Review, including:
  • Initial telephone interview to discuss your advisory business and compliance program
  • Form ADV review and the completion of any necessary changes on IARD or Part II
  • Compliance manual (Policies and Procedures) review
  • Advisory contract(s) review
• If requested, ACA shall provide on-going updates and advice related to the maintenance of the Compliance Manual and Form ADV

Compliance Assistant™

A product that offers investment advisers access to ACA's compliance professionals.

• Unlimited Customized Telephone Consulting
• Access to ACA’s Library of Compliance Documents
• ACA Insight Subscription (weekly compliance newsletter)
• Periodic Email Compliance Alerts

Off-Site Compliance Review

Investment advisers can retain ACA to conduct a focused off-site review of their operational and compliance risks.

• Conduct initial telephone interview to discuss your advisory practice
• Review Form ADV and the completion of any necessary changes on IARD or Part II
• Review written supervisory procedures and the completion of any recommended changes
• Review and analyze advisory contracts

SMART Solution

Available only to advisers managing less than $150 million, an ACA consultant will provide thorough assistance to advisers who need help completing the annual review. In two days advisers will learn how to:

• Perform Self-Assessments
• Conduct a Risk Inventory
• Ensure Polices and Procedures Address Compliance Risks
• Interview Staff
• Properly Document and Summarize Report Findings and Recommendations
• Highlight Internal Controls in Place to Mitigate Compliance Risks

Compliance Testing Plan

ACA will develop a testing plan that will include a variety of detailed testing options that can be used by advisers to evaluate the effectiveness of their compliance policies and procedures. Areas covered include, but are not limited to:

• Brokerage Selection and Best Execution
• Portfolio Management
• Code of Ethics and Personal Securities Transactions
• Insider Trading
• Marketing
• Pricing/Valuation
• Books and Records
• Regulatory Filings and Disclosures

Registration Solutions

Registration Accelerator™

ACA's Registration Accelerator™ is a one-year compliance solution that alleviates the initial registration compliance burdens and includes the following:

• Conduct initial telephone interview to discuss your advisory practice
• Prepare and file the Entitlement Forms with FINRA (if necessary)
• Prepare and file Part 1A (and 1B if applicable) of Form ADV on the IARD, including all applicable schedules;
• Prepare Part II of Form ADV
• Registrations of up to five investment adviser representatives (“IARs”) who will transact business on behalf of the firm
• Provide unlimited organizational and start-up consulting until approval of your investment adviser registration
• Unlimited Customized Telephone Consulting
• Template Compliance Manual
• Access to ACA’s Library of Compliance Documents
• ACA Insight Subscription (weekly compliance newsletter)
• Periodic Email Compliance Alerts
• IARD Administration

Singular Registration Solution

This solution will be provided to any firm that doesn't wish to retain ACA's on-going compliance consulting services.

• Conduct initial telephone interview to discuss your advisory practice
• Prepare and file the Entitlement Forms with FINRA (if necessary)
• Prepare and file Part 1A (and 1B if applicable) of Form ADV on the IARD, including all applicable schedules
• Prepare Part II of Form ADV
• Registrations of up to five investment adviser representatives (“IARs”) who will transact business on behalf of the firm
• Provide unlimited organizational and start-up consulting until approval of your investment adviser registration
• Template Compliance Manual
• Access to ACA’s Library of Compliance Documents