Compliance Solutions
Compliance Solutions
Vigilant helps Registered Investment Advisers (“RIAs”) and Broker Dealers operate within the bounds of regulations and guidelines, offering compliance solutions to protect your company. Our clients are from around the globe, ranging from Start-Ups to Multi-Billions in Assets Under Management (“AUM”). Our team of compliance professionals include many respected industry leaders and veterans who have served as Chief Compliance Officer (“CCO”) with extensive compliance expertise. We follow best practices to help your business succeed while providing best in class, high touch, customized CCO Services.
You can find solutions to all your compliance issues with Vigilant. Our capabilities range from Outsourced CCO to Distributor Solutions. We tailor our solutions to your unique needs with the aim of strengthening your business for the future.
Investment Advisers (RIAs)
Every RIA needs strategic planning and in-depth analysis from its CCO. This individual helps you comply with financial regulations, safeguarding your reputation and allowing you to grow.
In today’s aggressive regulatory environment, RIAs need to be closely monitoring new rules and regulations that are coming into effect. As an RIA registered with the SEC, you are required to have a named CCO on the ADV. Whether you need an Outsourced CCO or CCO Support, having a partner to help not only strengthen your compliance program but also monitor the new rules and regulations closely is crucially important.
With a variety of Investment Adviser Compliance Services, we help you plan for growth by managing your compliance program closely. Vigilant can either manage your entire compliance program or provide you with select support through the following:
- Full Service Compliance Support to in-house Chief Compliance Officer (“CCO”)
- Utilize an expert staff of compliance experts without building a cost center
- Vigilant under the direction of the in-house CCO will perform all SEC compliance related obligations
- Including but not limited to, Annual Rule 206(4)-7 Report, Risk Assessment Matrix, Compliance Calendar Management, Key Vendor Due Diligence, Regulatory Filings, Code of Ethics & Personal Trading Management, Compliance Training, Cybersecurity Assistance, etc.
- Interim Outsourced CCO
- Flexible availability of expertise over a short to interim time period.
- Outsourced CCO
- Provides need for firms with limited resources and/or in-house expertise.
- Specialized Compliance Consulting Services is another service model of Vigilant that is tailored to support firms on their targeted needs throughout their Compliance Program.
- Industry Best Practice Reviews of Private Equity Compliance Programs
- Mock SEC Examinations
- Mock SEC Interviews
- Tailored SEC Document Request Lists
- Formal Written Reports Evidencing such Reviews and Recommendations
- Web CRD, IARD, and Edgar Management
- SEC Registration & Exempt Reporting Adviser Registration (ERA)
- Form ADV Annual & Updating Amendments
- Form PF Filings
- Section 13 Filings (e.g., 13F, 13H, 13D, 13G), as applicable
- Select Additional Filings
- Assistance and/or Management of SEC Examinations
- Supporting Documentation Compilation
- Supporting Documentation Review
- Drafting and Review of Submittal Letter
- Interview preparation
- Participation in Regulatory Examination Calls/Meetings
- Creation of Day 1 SEC Presentation
- Expert Consultant in SEC Enforcement Actions
- Security Breach Response Assistance
- In-person & Select Electronic Training
- Compliance Training
- Code of Ethics, Conflicts of Interest and Personal Trading Training
- Insider Trading and MNPI Training
- Online Cybersecurity Training Platform
- Automated Phishing Tests
- Industry “Hot Topic” Trainings (e.g., Expense & Investment Allocation, Relevant SEC Enforcement Actions, etc.)
Private Equity Advisers
Private Equity Advisers require individuals with deep expertise, specifically in the Private Equity space and especially when serving as Adviser CCO.
With the ever changing rules and regulations, having a knowledgeable compliance team is paramount.
Vigilant has deep Private Equity experience providing CCO Services from Outsourced CCO to CCO Support. With over 500+ years of experience in the industry, you can trust Vigilant to provide you with a compliance team that is experienced and knowledgeable. In doing so, we are happy to have you meet the compliance team prior to utilizing us.
Learn more about our Private Equity CCO Services below and how we can help.
Hedge Funds and Hedge Fund Advisers
Having a high quality compliance program gives you a competitive edge. We can help you maintain your compliance program amid the unique risks incurred by Hedge Funds. Our professionals also aid you with complex transactions and prepare accurate filings.
Vigilant has been recognized in the Hedge Fund Industry for the following awards:
- Award Winner:
- With Intelligence Hedge Fund Manager (HFM) US Services Awards 2024 (Best Advisory Firm – Regulation and Compliance)
- Hedgeweek US Overall Awards 2024, in conjunction with Bloomberg (Best Regulatory Advisory & Compliance Firm)
- Hedgeweek US Overall Awards 2023, in conjunction with Bloomberg (Best Regulatory Advisory & Compliance Firm)
- Hedgeweek US Emerging Manager Awards 2023, in conjunction with Bloomberg (Best Outsourced Solution and Best Regulatory Advisory & Compliance Firm)
- Hedgeweek US Overall Awards 2022, in conjunction with Bloomberg (Best Regulatory Advisory & Compliance Firm)
Learn more about our high touch CCO Services and meet your proposed compliance team here.
Closed End Funds and Closed End Fund Advisers
Vigilant currently serves as both Outsourced CCO and CFO/PFO for Closed End Funds and Advisers, providing guidance and advising on regulatory, operational, and governance matters. Additionally, Vigilant provides the following Services:
- Adviser CCO and CFO Support Services
- Outsourced Fund CCO and CFO Services
- Investment Adviser Compliance and Oversight
- Fund Registration Support
- Service Provider Selection and Due Diligence
- Service Provider Integration and Coordination
There are three types of Closed End Funds below that we commonly work with:
Interval Funds and Tender Offer Funds represent subsets of Closed-End Funds. These Funds, under Rule 415 and Rule 486 under the Securities Act of 1933 and Rule 23c-3 under the Investment Company Act of 1940, may continuously offer their shares and make offers to repurchase shares at net asset value (NAV).
All Equity Closed-End Funds are subject to the risk that the portfolio securities held by the Fund will decline in value, thus causing a decline in the Fund’s NAV and market price. The value of a particular stock in a Fund’s portfolio may increase or decrease for a variety of reasons, including the business activities and financial condition of the issuer of the stock, market and economic conditions affecting the issuer’s business, or the stock market generally.
All Fixed-Income Closed-End Funds are subject to some degree of market risk and credit risk. Market risk is the risk that interest rates will rise, lowering the value of Bonds held in the Fund’s portfolio. Generally speaking, the longer the remaining maturity of a Fund’s portfolio securities, the greater the volatility of its NAV due to market risk. Credit risk is the risk that issuers of bonds held by the Fund will default on their promise to pay principal and interest. A Bond Closed-End Fund’s investment policies typically define the credit quality and maturity of the investments the Fund may make.
Exchange Traded Funds (“ETFs”)
The sharp rise in the popularity of ETFs sparked the adoption of Rule 6c-11. Your firm may have its own ETF or sell products another firm manages. Our solutions can assist with either, including submissions to the Financial Industry Regulatory Authority (“FINRA”) to ensure your sales and market campaigns comply with regulatory requirements and reviewing fund service providers.
With a common trend of Mutual Fund to ETF conversions, Vigilant was one of the first to go through that with one of our clients. We work with ETFs and ETF Advisers ranging from Start-Ups to Multi-Billions in Assets Under Management and have a variety of CCO Services to help fit within both your needs and budget.
Contact Us today if you are in need of CCO Services or Principal Underwriter (Statutory Distribution) Services for your ETF(s).
Mutual Funds and Mutual Fund Advisers
Mutual Funds and Mutual Fund Advisers that demand compliance oversight can benefit from our high touch CCO Services, which outlines the information you need to remain in compliance and plan for the future. We can:
- Resolve SEC inquiries.
- Review marketing sources.
- Offer code of ethics and insider trading training.
- Create quarterly compliance reports for your board.
- And much more.
We provide value in our CCO services by offering an array of benefits below:
- Proactive Approach
- Access to Expertise
- Dealing with Regulators
- Scaling Flexibility
- Significant Cost Savings compared to an In-House Solution
Real Estate Funds and Advisers
Vigilant helps both existing RIAs and Real Estate Firms that are not currently registered and are evaluating if they need to be SEC Registered. Since there are certain exemptions for Real Estate Funds, we help assess firms’ structures to see if they are required to be registered with the SEC.
Headed up by our Managing Director of Real Estate Fund Solutions, Bernadette Murphy, MSL, we provide deep experience and knowledge in Real Estate Fund rules and regulations.
Through our deep experience, we work with a variety of Real Estate Fund structures below (although not limited to):
- Private and Public Real Estate Lending Funds
- Private Equity Real Estate Funds
- Real Estate Joint Ventures
- Vertically integrated Commercial Real Estate Advisers
- Investment Advisers to ERISA and Government Pension Funds
- Special Opportunities Real Estate Investment Funds
Whether you need an Outsourced CCO or need Support for your in-house or dual-hatted CCO, we are here to help end to end.
Broker-Dealer
Broker Dealers are subject to strict compliance requirements to safeguard the interests of their clients as well as protect firm assets. We provide many Broker Dealer Compliance Services, such as:
- Outsourced CCO or CCO support.
- Broker Dealer Registration with FINRA (New Membership Application – NMA).
- Mock FINRA Exam.
- Financial Operation Principals (FinOp).
You may be subject to penalties if you violate SEC rules governing broker-dealers. We can help you determine if you are a broker and how to register, as well as provide ongoing CCO Services thereafter registration or for existing Broker Dealers.
Mock SEC Exams
Can your firm pass an SEC exam? Our program can prepare you with a Mock SEC Exam that follows SEC procedures. In any given year, Vigilant may see 15-25 SEC Exams, which means we will provide you with a custom, tailored initial request list to match your firm and its overall structure.
We test your compliance program and judge how it stands up to SEC policy. Our Mock Exam allows your associates to refamiliarize themselves with regulatory guidelines and lets you put new procedures in place to enhance your operations while complying with SEC laws. We perform reviews that includes a thorough high level review of the documents provided from the request list, interviews with key personnel and a written report of our findings and recommendations.
Registered Investment Adviser (“RIA”) Registration
When you search for a new advisory firm, you need experienced, knowledgeable professionals to guide you through the regulatory challenges. Vigilant offers SEC Registration Services to seamlessly help draft policies and procedures, file forms and respond to regulatory comments. We can also provide training for your staff and partners.
Once you become SEC Registered, you are required by the SEC to have a named CCO on the ADV. If you do not have the internal expertise to do so, Vigilant can be a cost-effective solution compared to bringing on an in-house CCO while still providing you with an industry veteran to serve in that capacity. If there is someone at the firm who is comfortable being the name CCO but still needs support, we do so for our clients on either an end-to-end or more limited basis.
Learn more about the initial and on-going Registration requirements and how we can help below.
Get Started With Vigilant Today
Our unparalleled knowledge and experience can help your firm remain in compliance and avoid regulatory headaches. By learning your firm’s history and culture, our professionals can operate at a level you feel comfortable with while preparing you for future growth. Contact us today to request a proposal tailored to your firm’s needs.
