PRIVATE FUND SERVICES

Compliance Solutions

C3 Select

This service is offered exclusively to private fund managers who are unregistered or to registered hedge fund managers who have retained knowledgeable in-house compliance and/or legal professionals.

• Semi-annual on-site focused compliance testing (3 days per on-site visit)(oral report only)
• Unlimited Customized Telephone Consulting
• Access to ACA’s Library of Compliance Documents
• ACA Insight Subscription (Weekly Compliance Newsletter)
• Periodic E-Mail Compliance Alerts
• Personal Securities Transaction Review
• On-Going Marketing and Advertising Review
• Initial and On-Going Review of Offering Documents for potential conflicts of interest
• Initial and On-Going Form ADV Review (if/when applicable)
• Customized Compliance Manual – Amendment to current procedures as may be necessary
• Filing of Form 13F and Schedule 13G (if applicable)
• Annual Employee Compliance Training
• Access to ACA Compliance Webcasts

Private Fund Inspections

ACA’s private fund 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 Advisers Act, 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

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
• Unlimited Customized Telephone Consulting
• Access to ACA’s Library of Compliance Documents
• ACA Insight Subscription (Weekly Compliance Newsletter)
• Periodic E-Mail 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.
• Access to ACA’s Library of Compliance Documents