2016 Compliance Survey for Alternative Fund Managers

September 7, 2016

Are you interested in how your firm's approach to its compliance program compares to your peers? Ever wonder what controls other private fund managers have implemented to safeguard client assets? Are you curious about what practices or controls peer firms have implemented surrounding personal trading? Are your anti-money laundering practices in line with other alternative fund managers?

If these questions interest you, ACA Compliance Group invites you to participate in our new ACA Alternative Fund Manager Survey. This is the seventh survey of our ongoing series and is focused on the compliance practices, processes, and procedures of hedge fund and illiquid fund (e.g., private equity, real estate, venture, infrastructure) managers. During ACA’s previous iteration of this survey series in March 2016, we received nearly 280 responses.

As with the previous assessments, at the conclusion of this survey, ACA will host a free webcast solely for participants. During this event, our consultants will discuss the survey results and provide best practice tips based on our expert analysis of the information collected.


ACA has designed its alternative fund manager surveys to explore and explicate the unique, complex issues faced by hedge fund and illiquid fund compliance professionals. Our current survey covers these important topics:

  • Compliance Program Rule – In this area, the survey covers the role of the chief compliance officer, compliance budgets and resources, annual compliance reviews, and the implementation of a compliance and forensic testing program.
  • Custody and Safekeeping of Client Assets – This segment centers on compliance with the GAAP audit requirement for private funds and any SPV or co-investment vehicles, the cost of compliance with the SEC custody rule, policies and procedures related to the calculation and deduction of management and incentive fees, and capital control and reconciliation best practices.
  • Personal Trading – This section focuses on the firm’s definition of Access Person, the restrictions applied to personal trading activities, and the testing completed by compliance personnel.
  • Anti-Money Laundering (“AML”) – In this section, the survey covers the AML controls firms have implemented, including the adoption of policies and procedures, the use of third parties to to assist in AML testing and oversight, and the nature and frequency of Office of Foreign Asset Control (“OFAC”) checks.

Your participation in our survey will have multiple benefits. Our past respondents have said that answering the questions alone gave them valuable insight into how to apply various best practices to their compliance programs. In addition, the aggregated survey data will provide up-to-date benchmarks for compliance controls and testing practices specific to the alternative fund management industry; this information will be useful for periodic and annual reviews. The results may also assist firms in assessing the impact of existing and potential regulatory requirement on their businesses.


Important Information About the Current Survey

As mentioned above, after the survey closes, ACA will discuss the results in a free webcast for survey participants. This event will take place November 10, 2016.Participants will be redirected to register for the webcast upon completion of the survey. In order to receive complimentary access, please be sure to complete the registration before exiting the survey.

The survey takes approximately 30 minutes to complete. Partially completed responses cannot be saved, so please plan to answer all questions in one sitting.

The survey is open to compliance professionals at private equity, real estate, and hedge fund managers until October 14, 2016. We ask that only one person per firm complete the survey. If you are not your firm's chief compliance officer, please check with him or her before taking the survey to avoid duplicate responses.

ACA conducts its surveys in a "blind" manner where all respondents remain anonymous. You will not be asked to identify yourself or your firm at any point during the survey. All responses are strictly confidential. Responses may be shared with third parties at our discretion; however, they will remain anonymous and will not be attributed to the respondent.

Should any technical questions arise regarding the survey, please contact Danielle Joseph at (202) 713-8632.

Thank you in advance for your contribution.