Services
How Engagements are Structured
Engagements are tailored based on the scope of services, complexity of the business, and level of ongoing support required. Services may be delivered on a retainer basis or through project-based engagements, with flexibility to scale as the firm evolves.
Mock SEC Examination
I'm replicating the actual examination experience -- the document requests, the interviews, the pressure, the judgment calls examiners make in real time. My goal is to find what the SEC would find before they do, so you have the opportunity to fix it on your terms rather than theirs.
Scope includes:
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Initial document request replicating current SEC examination requests for your firm type
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Thorough review of your compliance policies, procedures, and Code of Ethics against current regulatory standards and recent examination priorities
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Testing of key controls including personal trading, marketing materials, valuation, and conflicts of interest
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Mock interviews with principals and key personnel to prepare your team for examiner questioning
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Written findings report identifying gaps, weaknesses, and areas of risk ranked by severity
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Debrief session to walk through findings and discuss remediation priorities
Engagements typically completed within 30 days. Contact us for a fixed fee quote.
Outsourced Chief Compliance Officer
Ongoing, senior-level oversight of your compliance program, structured to align with SEC expectations and institutional standards. This role provides consistent guidance, accountability, and coordination across all aspects of compliance.
Scope includes:
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Oversight and ongoing refinement of the compliance program
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Direct engagement with senior management on compliance matters
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Monitoring of regulatory developments and applicability to the firm
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Coordination of compliance activities across business functions
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Support in preparing for and responding to regulatory inquiries and examinations
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Periodic reporting to management or governance bodies, as appropriate
Compliance Program Design & Enhancement
Development and refinement of compliance frameworks tailored to the firm’s strategy, structure, and stage of growth.
Scope includes:
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Drafting and updating compliance manuals and core policies
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Structuring compliance frameworks aligned with Rule 206(4)-7 under the Investment Advisers Act
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Integration of compliance processes into day-to-day operations
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Development of procedures for monitoring, testing, and escalation
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Alignment of policies with institutional investor expectations
Regulatory Filings & Disclosure Oversight
Review and oversight of regulatory filings and investor-facing disclosures to ensure accuracy, consistency, and alignment with applicable requirements.
Scope includes:
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Preparation and review of Form ADV, Form PF and related filings
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Oversight of updates and amendments to regulatory disclosures
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Review of investor communications for consistency with disclosures
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Coordination of disclosure updates in response to business changes
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Identification and remediation of inconsistencies across documents
Ongoing Advisory
Day-to-day access to senior compliance guidance on regulatory questions, business initiatives, and emerging risks.
Scope includes:
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Interpretation of regulatory requirements in practical business contexts
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Review of new initiatives, products, or strategies from a compliance perspective
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Guidance on marketing materials and investor communications
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Support on ad hoc compliance questions as they arise
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Ongoing identification of emerging regulatory and operational risks
Governance, MNPI & Conflicts Frameworks
Design and implementation of governance structures and controls addressing material non-public information, conflicts of interest, and decision-making processes.
Scope includes:
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Development of MNPI controls and information barrier frameworks
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Identification and documentation of conflicts of interest
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Design of governance structures to support oversight and accountability
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Implementation of procedures for managing and disclosing conflicts
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Guidance on documentation of investment decisions and approvals
Bespoke Solutions
We also undertake targeted, bespoke engagements—such as Regulation S-P reviews, and other limited-scope assessments—where focused support is required.