GRC Solutions for Mutual Funds, ETFs, and Other Investment Companies

Our Investment Company Practice supports registered investment companies, as well as their advisers and sub-advisers, board of directors, and service providers to help them build, enhance and add controls to their compliance programs to meet Investment Company Act of 1940 requirements and SEC and industry standards.

We offer objective, innovative, and effective compliance reviews and solutions to prepare registered investment companies, as well as their boards, sponsors, advisers, sub-advisers, and service providers, for the rigors of SEC examinations. We provide solutions to assist firms with managing and mitigating related operational, regulatory, and reputational risks.

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Our solutions

Address financial crimes-related threats and regulatory concerns with our team of former regulators and auditors. Our team can support with independent money laundering reviews for mutual funds and transfer agents, AML compliance program reviews, and more.

We offer broker-dealer chaperoning services to non-U.S. asset managers and broker-dealers that seek to market private funds in the United States without registering as a U.S. broker-dealer.

Strengthen your compliance program with our global team of compliance professionals.

Our consultants can provide training on the many topics mutual funds, ETFs, and other investment companies need to comply with, or you can choose to use any of our online modules to train your staff.

Build cyber and operational resilience across your firm with our team of cybersecurity and technology risk experts.

ACA Foreside can sponsor (apply for, obtain, and maintain) an NSCC membership participant number for domestic funds, collective trusts, and foreign funds. Additionally, we can provide guidance to clients and their transfer agents with respect to administration, implementation, and maintenance of funds’ operational policies and procedures.

Gain clarity on your firm’s ESG requirements and build a strong compliance program with our dedicated ESG advisory practice.

Launching an ETF takes the right partner.  Our EFT compliance services stand ready to advise you regarding the regulatory, financial, operational and distribution requirements of your exchange-traded funds (ETFs). 

Our Fund Officer model provides a hands-on, tailored approach by placing experienced and independent Fund Officers close to the Fund’s Board of Trustees. They are exposed to multiple administrators, counsel, and advisors, and have valuable industry perspective allowing for a better understanding of best practices.

We distribute over $1 trillion of product for over 200 fund families through our broker-dealers and serve as the legal underwriter for registered funds (mutual funds, closed-end funds, and ETFs) and placement agent for private funds.

Liquidity Risk Management Program Support

ACA’s Investment Company practice is dedicated to supporting our clients in navigating the SEC’s liquidity risk management program rule through educational resources and alerts, benchmarking insight, help with program management and development of policies and procedures, annual assessments, and more.

Maximize your firm’s time and efficiency with our technology-powered managed services. Our team can assist with on- and off-site CCO support and outsourced mutual fund advertising and marketing reviews.

Stay in compliance with the GIPS® standards and investment performance rules with the world’s largest team of GIPS standards verifiers.

We can maintain a private-label broker-dealer on behalf of your firm, allowing you to focus on your core business. Our private label broker-dealer offering provides an opportunity for firms to have ACA Foreside own and manage a broker-dealer branded by you and dedicated solely to you as the client.

ACA Foreside can assist with all aspects of your FINRA licensing needs for both registered and private funds.

Build a scalable and resilient compliance program with our ComplianceAlpha® regulatory technology  platform backed by managed services support.

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Who we work with

We provide solutions for the following types of firms.

Business Development Companies (BDCs)

We provide objective, innovative, and effective compliance reviews and solutions to assist business development companies, as well as their boards, sponsors, and service providers — with preparing for the rigors of an SEC examination.

Exchange Traded Funds (ETFs)

We provide objective, innovative, and effective compliance reviews and solutions to assist exchange-traded funds with preparing for the rigors of an SEC examination.

Registered Investment Companies

We offer diverse compliance review and fund management compliance services, all scalable to individual client needs.

Variable Insurance Products

We help insurance companies and distributors understand and manage these complex compliance requirements and develop and implement the comprehensive, effective risk-based protocols necessary to meet regulators’ expectations.

Solution Spotlight

Investment company compliance solutions

Our fund management compliance team includes former regulators along with former along with former chief compliance officers and senior compliance managers from prominent financial institutions. Our team helps you to navigate the evolving regulatory landscape while considering the complexity of your firm’s unique compliance requirements.

Compliance solutions can include:

  • Adviser and fund policy and procedure customization and development
  • Mock SEC reviews
  • Rule 38a-1 compliance program reviews
  • Enhanced annual adviser compliance program reviews that is specific to Company Act requirements for advisers/sub-advisers
  • Customized focus reviews (e.g. liquidity risk management program, intermediary fees, cross trades, cybersecurity, valuation)
  • Compliance and internal audit testing support
  • Sub-adviser due diligence reviews
  • SEC inspection support
  • Mutual fund distributor reviews and financial intermediary oversight reviews (e.g. FINRA rule 3110, 3120)
  • Independent Consulting Mandate

By the numbers

Our market share

80%

of the top 100 mutual funds (as noted in the Mutual Fund Directory March 2020 ranking data)

Latest compliance insights

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OCIE Publishes Marketing Risk Alert

On September 14, 2017, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a National Exam Program Risk Alert related to Rule 206(4)-1 under the Investment Advisers Act of 1940 (the “Advertising Rule”). The risk alert highlights the compliance issues most commonly noted by the SEC’s examination staff as part of a recent “Touting Initiative.” That initiative, which consisted of reviews of approximately 70 investment advisers, focused on the use of “accolades” in advertising.

Compliance Alert
  • Compliance
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SEC Tightens Record-Keeping Requirement on RIAs Reporting Performance

The amendments to Investment Advisers Act Rule 204-2 will require advisers to maintain additional records related to the calculation and distribution of performance information.

Article
  • SEC
  • Compliance
  • Performance
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MiFID II for Asset Managers: Communications Record Keeping

Communications record keeping obligations which include phone taping, are likely to prove particularly challenging when it comes to the cost of compliance and complexity of systems requirements.

Compliance Alert
  • Compliance
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5 Ways to Meet Regulators' Expectations Regarding Electronic Communications

The electronic communication mediums that investment advisers use to conduct business continue to evolve, posing a challenge to the compliance community’s ability to retain and adequately supervise

Article
  • Compliance
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Calculating Assets Under Management vs. Assets Under Advisement

The SEC has been paying close attention to discrepancies in Form ADV filings, specifically reviewing assets under management. When Annual Updates are due, it’s important to pay close attention to how you calculate your regulatory assets under management (RAUM).

Article
  • Compliance
  • SEC
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Continuing Education – Regulatory Element vs. Firm Element

FINRA Rule 1250 requires registered persons to participate in Continuing Education (“CE”), with both Regulatory Element and Firm Element training. We break down these categories and how to differentiate them.

Article
  • Compliance

News

No Conversation Left Behind: ACA's Advanced Communication Channel Capture for Total Oversight

ACA Expands Communication Channel Capture to Strengthen Compliance Oversight

ACA Aponix Celebrates 10-Year Anniversary and National Cybersecurity Month

ACA Aponix Celebrates 10-Year Anniversary and National Cybersecurity Month. Reflecting on a decade of cybersecurity leadership, technological advancement, and industry recognition for financial services

Honoring the Legacy of Michael Lehman

ACA remembers and honors the life of Michael Lehman, the co-founder of Decryptex, now known as our Market Abuse Surveillance solution, a cornerstone of ACA’s ComplianceAlpha® platform today.

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