Dual-Hat CCO Support: How Vigilant Compliance Can Help
Vigilant Insights
Introduction
At Vigilant Compliance (“Vigilant”), our team of seasoned Compliance Professionals can provide a wide variety of services, enabling firms to navigate complex regulatory requirements efficiently. As a Privately Owned Firm, we maintain complete autonomy to serve your unique and specific compliance needs.
Below are examples of how Vigilant can be utilized to enhance and/or support your existing compliance program and help ensure your firm stays on track with the SEC’s Rules and Regulations.
7 Examples of Dual-Hat CCO Support
1. Regulatory Monitoring and Updates
- On-Going Regulatory Monitoring
- While it remains to be determined in this current regulatory environment, throughout the past four (4) years, the SEC and FINRA have constantly evolved their Rules and Regulations. An Outsourced Compliance Team can monitor these changes and ensure that your firm is always aware of any updates to SEC/FINRA Rules (as applicable to your business), including those related to disclosure requirements, reporting deadlines, and governance standards.
- Timely Updates
- Vigilant frequently tracks emerging regulations or guidance that may impact your business. Helping firms adapt quickly without needing to dedicate internal resources to constantly monitor regulatory changes is a significant value add.
2. Filing and Reporting Support
- Regulatory Filings
- Registered Investment Advisers (RIAs) often need to file reports such as Form ADV, Form 13F, Form PF and 13D/G. An Outsourced Compliance Team can support your firm with timely and accurate preparation of these documents, managing the aspects of the filings, including disclosures, financial statements, and supporting documents.
3. Internal Compliance Program Development and Management
- Compliance Framework Creation
- At Vigilant, our goal is to make as seamless of a transition that we can. We can either transition into the current Compliance Program that is in place or can help design and implement a robust compliance framework that is tailored to your firm’s specific needs. This includes reviewing and modifying internal policies and procedures to ensure that your firm adheres to relevant and applicable SEC Rules and Regulations.
- Risk Assessment and Mitigation
- Our team of Compliance Professionals can conduct thorough assessments to identify and mitigate regulatory and operational risks. They can ensure that potential risks (i.e., conflicts of interest) are proactively managed through the development of internal controls and monitoring systems.
- Compliance Training
- We can conduct Compliance Training with your team to ensure they are educated on the latest SEC regulations, compliance processes, and best practices. Regular training helps reduce the risk of violations by promoting a culture of compliance across the firm.
4. Mock Examinations/Best Practice Compliance Review and Monitoring Services
- Mock Examinations/Best Practice Compliance Review:
- Vigilant can perform a Mock Examination or Best Practice Compliance Review to review and assess the effectiveness of your firm’s existing compliance program. This can help identify gaps, weaknesses, or inefficiencies in the compliance framework, ensuring your firm’s practices align with SEC requirements. Support on addressing those potential gaps identified is also provided by Vigilant thereafter.
- On-Going Monitoring:
- Utilizing a Compliance Consultant for support allows for continuous monitoring of the firm’s activities, ensuring that regulatory requirements are being met. This includes tracking key metrics, transactions, or business processes to ensure they comply with SEC standards.
- Surveillance and Testing:
- External Compliance Teams can perform surveillance and testing on your firm’s operations to detect and prevent potential violations. This could include reviewing trading practices, investment strategies, or compliance with fiduciary duties under SEC Regulations.
5. AI and Cybersecurity Guidance
- AI and Cybersecurity Guidance
- Given the SEC’s increased focus on AI and Cybersecurity, Vigilant helps firms develop and implement AI and Cybersecurity policies and procedures that meet the SEC’s standards.
6. Regulatory Examination Support
- Regulatory Examination Support
- Vigilant has significant experience in dealing with SEC and FINRA Examinations. In any given year, we typically deal with 15-30 Examinations annually for our clients. If your Firm is subject to an SEC or FINRA Examination, we can provide support in responding to inquiries, internal interview prep, drafting a response letter and managing the process. This could include gathering documents, interviewing relevant staff, and providing regulatory advice and guidance.
- An outsourced team can guide a firm through the process of preparing for an SEC or FINRA examination, including reviewing the firm’s practices, policies, and records to ensure readiness. This includes preparing all necessary documents and ensuring that they are compliant with SEC or FINRA requirements.
- Remediation and Corrective Actions:
- If your firm was found non-compliant or received a regulatory notice, Vigilant has experience in assisting firms (that were previously not our client) with developing and implementing corrective actions, managing the remediation process, and ensuring that the issues identified are resolved efficiently to avoid potential penalties.
7. Third-Party Vendor Management
- Vendor Due Diligence:
- At Vigilant, we can conduct Due Diligence on Third-Party Vendors, ensuring they meet the applicable regulatory requirements and that no conflicts of interest or compliance risks arise.
- On-Going Monitoring of Third Parties:
- We can provide on-going support in regularly monitoring third-party relationships for compliance risks, ensuring that your firm maintains a compliant ecosystem, including any external vendors or partners.
Vigilant’s Conclusion
Our Compliance Support Services for Dual Hat CCO’s can be utilized in a variety of ways to help your firm comply with a wide array of SEC regulations, manage risks, and help ensure your compliance program is effective and up-to-date.
The outsourced Compliance Support model provides flexibility, cost efficiency, and specialized expertise, making it an attractive option for many firms, particularly those that are seeking to enhance their compliance program without the burden of maintaining an In-House Compliance Team.
By leveraging our Support Services, firms can focus on their core business activities while staying compliant with complex SEC regulations.
Ready to help alleviate the Compliance burden you are currently dealing with? Schedule a call with a member of our Team today by clicking the button below.