ETF (Exchange Traded Funds)
ETF Compliance Services
Vigilant is an Award Winning and Industry Leading Compliance Firm that continues to remain Independent and Privately Held delivering Clients with end to end Solutions that they can trust. Our clients advise or distribute billions of dollars of Exchange-Traded Funds (ETF) every year. Vigilant is well versed in the unique needs of investment managers working with these products. These include the requirements of Rule 6c-11, exchange listing standards, and other requirements applicable to Fund Boards and Investment Advisers to these products.
Vigilant’s ETF Group currently serves as Outsourced CCO and CFO providing guidance and advising on regulatory, operational and governance matters that include the following:
- Adviser CCO and CFO Support Services
- Outsourced Fund CCO and CFO/PFO Services
- Investment Adviser Compliance and Oversight
- Fund Registration Support
- Service Provider Selection and Due Diligence
- Service Provider Integration and Coordination
As ETFs have exploded in growth during the last 15 years, culminating in Rule 6c-11’s adoption, Vigilant has worked with numerous companies including those managing more complicated, actively managed and leveraged ETFs that require tailored and customized compliance policies and procedures, and often receive additional regulatory scrutiny.
Our experienced professionals, who hail from the financial and accounting industries, give you the insight and expertise needed to grow your business comfortably, knowing that your compliance program is in good hands.
Vigilant’s ETF Compliance Services
Whether your business sells ETF products managed by another firm, or you’d like to develop your own ETF, Vigilant can help. Our ETF specific solutions include:
- Review and Submission to FINRA, if applicable, of sales and marketing materials and campaigns to assure compliance with all applicable laws and regulatory requirements.
- Development of a comprehensive compliance program including Rule 6c-11, Liquidity Risk Management, and Index Provider Review policies.
- Reviewing Fund service providers, including Index Providers or Calculation Agents, as an SEC best practice.
Protect Your Firm With ETF Compliance Services
Any firm that outsources SEC compliance to Vigilant helps reduce the risk of violating federal and state regulations and incurring costly penalties. Our ETF Compliance Services can also offer a host of additional benefits including:
- Access to Expertise: Our ETF Compliance Consultants stay abreast of the regulatory changes, preventing your firm from committing an unintentional violation.
- Cost Savings: Outsourcing is often more affordable than hiring and maintaining an in-house compliance officer or team. You’ll avoid paying for add-ons like fringe benefits and bonuses, and you won’t incur the costs associated with employee turnover.
- Proactive Approach: Firms may not recognize a compliance violation until it’s too late. Our ETF Compliance Consultants have the experience to anticipate potential issues and implement preventive measures.
- Dealing with Regulators: The SEC and other regulatory agencies have strict protocols for responding to inquiries, reporting and filing documents. Our in-depth knowledge of the system and how it works can save time and prevent costly mistakes.
- Scaling Flexibility: As your firm grows, your compliance concerns and needs will likely increase. Vigilant has the resources to scale quickly to keep pace with your evolving requirements.
Frequently Asked Questions
Click on a question below to view answers to questions Vigilant frequently receives.
Can Vigilant assist with launching a new ETF?
Yes. Whether you’re launching your first ETF or expanding an existing product lineup, Vigilant provides tailored Services to help prepare your Firm and Fund for on-going regulatory responsibilities. This starts with development of Compliance Policies and Procedures, Registration, and on-going Compliance (Adviser/Fund CCO, Principal Underwriter, Registered Representative) needs.
Does Vigilant have experience with 351 (SMAs) exchanges and mutual fund to ETF conversions?
Vigilant has experience supporting firms through both 351 (SMA) Exchanges and Mutual Fund to ETF conversions, providing compliance guidance tailored to each Firm’s unique structure and objectives.
Can Vigilant help with Rule 6c-11 compliance considerations?
Yes. Vigilant provides compliance support to help ETF Sponsors navigate the regulatory considerations associated with Rule 6c-11 and on-going ETF operations.
Can Vigilant assist with marketing and advertising reviews for ETFs?
Vigilant provides Marketing and Advertising Review Services serving as Principal Underwriter to help ETF Sponsors/Advisers evaluate communications for compliance with applicable regulatory requirements and industry standards.
Learn more about our Marketing Review Services here: Marketing Compliance Review Services | FINRA & SEC Expertise
Can Vigilant support sponsors that plan to launch multiple ETFs over time?
As ETF sponsors introduce multiple Funds over time, Vigilant can provide flexible compliance support designed to scale with their organization. Vigilant works with Industry Recognized ETF Firms in the space, often from inception, being a scalable Partner as the Firm continues to grow and add multiple Funds over time.
Contact Vigilant for More Information
With team members in New York, Philadelphia, Boston, Texas, Metro Washington, D.C., Pittsburgh, Tennessee, Georgia, Florida and around the nation, Vigilant is well positioned to help your business create and sustain an effective ETF Compliance Program.
Contact Vigilant today to learn more about how we can help with a new Fund launch or on-going Compliance.
Related Vigilant Insights
Read all insights
ETF/Mutual Fund Dual Share Class Anticipated Approval | Salvatore Faia Insights
April 28, 2025 ETF/Mutual Fund Dual Share Class Anticipated Approval | Salvatore Faia Insights
View full article
Maximize Compliance Efficiency: The Case for an Outsourced CCO
April 7, 2025