Insights from Chuck Martin
Chuck was quoted, saying that his thoughts on the Adviser’s Derivatives Risk Manager that must have relevant experience.
He stated, “Given that the rule requires whoever is named as the adviser’s derivatives risk manager must have “relevant experience,” the job isn’t going to the CCOs. The task can’t fall to a portfolio manager, so an exception can occur at very small shops where no one else but the CCO is available to wear the hat.”
Insights from Ryan Hurley
Ryan was quoted regarding the CCO’s role where he emphasized the importance to make sure Firms have practiced their abilities leading up to the Compliance Date.
He suggested that in the days prior to the Rule being effective, “In the days before the rule takes effect, practice your firm’s ability to get and analyze the data, conduct daily testing and track derivatives’ thresholds.”
Vigilant’s Final Conclusion
For Firms that manage a Registered Fund including these instruments, it is important to be aware that the Derivatives Rule is now in effect.
If you have any questions or need assistance, do not hesitate to reach out to Vigilant as we are happy to help.