Mutual Fund

Mutual Fund Compliance Solutions

Vigilant provides outsourced Chief Compliance Officers for Open-End Mutual Funds, Closed-End Mutual Funds, and Multi-Series Trust. Critical to the effective performance of the CCO function is oversight of Mutual Fund service providers—the Fund Adviser, Fund Accountant, Administration, Custodian, Transfer Agent, Distributor, and Principal Underwriter. A Fund’s Compliance with the Investment Company Act of 1940, the Securities Exchange Act of 1934, the Securities Act of 1933, and other Regulations takes careful analysis and planning—and Vigilant brings both to Funds.

Vigilant’s 5 Step Matrix SystemSM will provide you a guideline of what we have to offer.

Assess and Create
  • Conduct specialized meeting with Fund Officers and Advisers to determine your specific Compliance needs
  • Designate a qualified Professional to serve as your Chief Compliance Officer with a dedicated support team
  • Craft your Fund Compliance Manual, Policies and Procedures
  • Prepare a Customized Fund Risk Matrix
  • Prepare and Maintain Fund Compliance Calendar
  • Leverage Vigilant’s experience and relationships with Funds and Service Providers in the Industry to Establish Best In Class Processes
Manage and Review
  • Conduct Compliance Review and Testing of All Critical Fund Areas
  • Review and document Compliance with the SEC’s Required Areas for Funds including:
    • Portfolio Management
    • Brokerage Arrangements and Best Execution
    • Trade Allocations
    • Personal Trading by Access Persons
    • Pricing
    • Safety of Fund Assets
    • Marketing and Distribution
    • Shareholder Order Processing
    • Books and Records
    • Information Reporting and Corporate Governance
  • Review Fund Adviser Compliance initially and annually with the SEC’s Required Areas of:
    • Portfolio Management
    • Trading, Best Execution, Allocation & Soft Dollar Usage
    • Safety of Assets
    • Personal Trading by Access Persons
    • Disclosure Accuracy
    • Marketing and Advisory Services
    • Privacy
    • Books & Records
  • Conduct On-Site Compliance Due Diligence of:
    • Fund Adviser
    • Fund Accountant
    • Administration
    • Custodian
    • Transfer Agent
    • Distributor
    • Principal Underwriter
  • Continuously Update Fund Compliance Policies and Procedures, Risk Matrix and Compliance Calendar Based on Changing Regulatory Requirements
  • Craft Specialized Policies and Conduct Reviews in the Areas of:
    • Cybersecurity
    • Liquidity Risk Management
    • Derivatives and Section 18(f)
    • 22c-2 – Market Timing
    • Adviser Soft Dollars
    • Adviser Best Execution
    • Gifts and Entertainment
  • Review of Marketing Materials for Compliance with SEC and FINRA Rule
Educate and Train
  • Conduct Required Code of Ethics Training for Fund Board Members and Directors
  • Train Officers and Employees on SEC Requirements Applicable to Specific Areas
  • Educate Board Members regarding new applicable regulatory requirements
Report and File
  • Prepare and Analyze Quarterly Adviser and Service Provider Compliance Questionnaires
  • Quarterly Report on Fund Adviser Areas of Note such as:
    • Affiliated Transaction
    • Soft Dollars Payments
    • Regulation Examinations
    • Illiquid Securities
    • Compliance Violations
    • Business Continuity Events
    • Cybersecurity Issues
  • Prepare Quarterly Chief Compliance Officer Review Reports and Status Memorandums
  • Prepare Annual SEC Rule 38a-1 Report
  • Attend Board, Audit and Special Committee Meetings
  • Review of Required Timely Filings such N-CSR, N-CEN, N-PORT and N-LIQUID
  • Conduct Disclosures Controls and Procedures Meetings
Respond and Resolve
  • Analyze Material Matters, NAV Errors and other Compliance Issues
  • Respond & Provide Documentation related to Fund Auditor Requests
  • Respond & Resolve SEC Inquiries and Examination
    • Investment Companies made the SEC’s 2020 Examination Priority List

We Have the Knowledge and Skills You Need

At Vigilant, we have the knowledge and skills you need to build a stronger future. With offices in New York, Philadelphia, Boston, Dallas and Washington, D.C., Vigilant is well positioned to help your business create and sustain an effective compliance policy. Contact Vigilant or call 1-888-229-1855 and find out how we can help you protect your interests.