Outsourced Compliance: When Is the Time Right?
Vigilant Insights
Introduction
For many Investment Advisers, the question is not whether Compliance is important, it is whether the Firm has the right resources, experience, and infrastructure to manage its compliance responsibilities effectively.
We believe Outsourced Compliance is a valuable option which provides value regardless of the Firm’s lifecycle. It can provide additional support during periods of growth, organizational change, increased regulatory expectations, or when a Firm simply needs experienced compliance resources without building a larger internal team.
Timing Examples of When Outsourced Compliance is Used
- Launching a New Firm or Strategy
- Establishing a Compliance Program from the beginning.
- Supporting SEC Registration and initial regulatory requirements.
- Building policies, procedures, and compliance processes.
- Firm Growth
- AUM or the number of clients is increasing.
- The Firm’s business model or investment strategies are becoming more complex.
- Existing compliance resources are becoming stretched.
- Adding New Products or Strategies
- Launching 40 Act Funds, Private Funds, SMAs, or other investment strategies.
- Expanding into new markets or business lines.
- Reviewing whether existing policies and procedures address the Firm’s activities.
- Preparing for an SEC Examination
- Conducting a Mock Exam.
- Identifying and addressing potential compliance gaps.
- Organizing policies, records, and testing documentation.
- Transitioning Compliance Personnel
- A CCO or other Compliance Professional leaves the Firm.
- The Firm is between CCOs or looking for a permanent solution.
- Additional resources are needed while an internal team is established.
- Supporting an Existing Compliance Team
- An internal CCO needs additional expertise or capacity.
- The Firm wants a second set of eyes on key compliance matters.
- Specialized resources are needed for areas such as marketing, cybersecurity, or regulatory filings.
Common Areas Where Vigilant is Used
Vigilant can support Advisers across a broad range of compliance needs, including:
- On-Going Compliance Program Management
- Annual Compliance Reviews and Testing
- SEC Examination Preparation and Mock Exams
- Policies and Procedures
- Form ADV and Regulatory Filings
- Marketing and Advertising Reviews
- Private Fund Compliance
- Cybersecurity Oversight
- Code of Ethics Administration and Testing
- Compliance Training
- Vendor and Service Provider Oversight
- Compliance Monitoring and Reporting
How Vigilant Can Help
Outsourced Compliance does not have to mean giving up control of the Firm’s compliance program. For many Advisers, it provides access to experienced Compliance Professionals who can help manage day-to-day responsibilities while working alongside Management and Investment Personnel.
Vigilant can provide Outsourced CCO Services, targeted Compliance Support, or additional resources for an existing compliance function. Our approach can be scaled based on the Firm’s needs and adjusted as those needs change.
Whether a Firm is launching, growing, preparing for an examination, navigating a transition, or simply looking for additional compliance resources, the right time to consider Outsourced Compliance is when the Firm’s compliance needs begin to exceed the resources available internally.
Schedule a call with Vigilant to learn more about our Compliance Services and how we can help.