Private Equity Compliance
Private Equity 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 experienced compliance professionals serve as Outsourced Chief Compliance Officer (OCCO) and provide Compliance Support (CCO Support) for Private Equity Advisers, including Private Equity, Private Credit, Structured Credit, Infrastructure, Co-Investment, Venture Capital, Real Estate Funds, and other Private Funds.
Our client size ranges from start-ups to multi billions in assets under management (AUM).
Through the following suite of services, Vigilant can either manage your entire compliance program or provide you with select support through the following:
Vigilant’s Suite of Private Equity Compliance Services
- 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 Fund Advisers require specialized Compliance Programs due to their often complex legal structures and unique investment styles. Vigilant is experienced in developing and operating Compliance Programs for Private Equity Advisers as well as registering them.
Key Compliance Considerations for Outsourced Compliance
When partnering with Vigilant, we allow Private Equity Advisers to focus on managing their Fund(s), growing their Limited Partner (“LP”) base, and other core competencies.
Our team of experienced compliance professionals have extensive experience in managing and supporting the compliance programs of Private Equity Advisers and are prepared to provide you assistance in a wide array of Private Funds Compliance Services.
Common questions we see asked by firms considering outsourcing are:
- Do we have enough internal resources or the right external resources in place?
- Can we keep up with the regulatory requirements not only today, but in the future, as we grow and our regulatory obligations increase?
As it relates to the compliance requirements and risks associated with Private Equity Advisers and Funds, Vigilant is well versed in supporting a variety of firms with different investment strategies and structures.
Specifically to Private Equity Firms, Vigilant assists Clients in:
- Managing and disclosing conflicts relating to allocating investments across multiple Funds.
- Properly disclosing co-investments or other special purpose vehicles (SPVs).
- Properly allocating fees and expenses among Funds, Portfolio Companies, and the Adviser.
- Adequately disclosing and supervising Operating Partners, or individuals who provide solutions to the Funds or Portfolio Companies, but who are not employees.
- Providing proper training and oversight over employees and establishing written policies and procedures designed to prevent the misuse of Material Non-Public Information (MNPI).
- Conducting Marketing and Advertising Reviews, including the methodologies for calculations that are gross and net IRR (i.e., Calculations Performance without and with the impact of Fund-level subscription facilities).
Additionally, Vigilant can help Clients:
- Develop and implement written compliance policy and procedures that meet or exceed current rules and regulations. Our experienced consultants will review your business plan or existing operation and devise a strategy that assures your commitment to secure, ethical and legal practices.
- Review and amend your existing policies and procedures to meet Adviser Act requirements. It is in the best interests of your clients and your firm that your business encourages a culture where compliance forms the foundation of your reputation. Our consultants will review your existing policies and procedures, identify potential problems and design the policies and procedures that will help your business grow, safely and securely.
- Assist and manage Code of Ethics requirements.
- Conduct mock SEC exams. Assure thorough preparation for your upcoming SEC exam with training from Vigilant, including mock SEC exams that measure retention and performance.
- Review your marketing, advertising and communications materials. Registered Investment Advisers must adhere to strict regulations when communicating with clients and the public. Ask us to review your marketing and communications strategies to assure your compliance with the Act.
- Prepare and submit accurate filings. Vigilant prepares, reviews and files Form ADV, Form PF, and other applicable filings forms on behalf of our clients.
- Investigate past practices and transactions. Vigilant provides thorough forensic compliance solutions.
- Complete 206(4)-7 Compliance Report.
Most Firms Come to Vigilant for On-Going Compliance
Most firms find our on-going compliance support integral in managing their regulatory obligations. We work with many new and established Private Equity Advisers to help stay within compliance and follow the rules and regulations through our end-to-end Compliance Solutions.
Contact Vigilant
Vigilant is a full service Compliance Solutions Firm servicing the regulatory needs of a diversified range of investment management and financial services clients.
We help with Private Equity Compliance, Private Fund Compliance Consulting for Private Equity Firms, and additional compliance needs. 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 Private Equity Compliance Program.
For over 20 years, Vigilant has been a leader among regulatory compliance consulting firms; uniting regulatory compliance and financial expertise paving the way to the Market for our clients.
Contact Vigilant for a complimentary consultation at 1-888-229-1855.
