Senior management in Financial Services firms have a responsibility to ensure their employees have sufficient knowledge and understanding of the Regulatory environment they are working in. This knowledge helps in emphasising the need for compliance with policies and procedures in order to protect the firm and the individual from failing to “do the right thing”.
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.
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.
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.
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.
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.
Who we work with
We provide solutions for the following types of firms.
Business Development Companies (BDCs)
We provides 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 CompaniesWe offer diverse compliance review and 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.
Investment company compliance solutions
Our 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
of the top 100 mutual funds (as noted in the Mutual Fund Directory March 2020 ranking data)
Latest compliance insights
The NFA issued a Notice to Members on February 1, 2022, extending relief from performing on-site annual branch office inspections.
SEC’s Examination Division Shares Observations Relating to Common Deficiencies Uncovered in Private Fund Manager Examinations
On January 27, 2022, the SEC’s Division of Examinations (EXAMS) shared observations relating to common deficiencies uncovered in the examination of private fund advisers over a five-year period. These observations are a sequel to, and supplement, the observations EXAMS shared in their June 2020 risk alert. In our in-depth analysis, we cover what firms need to know about this risk alert.
ACA Group research has detected more than 6 million transaction reporting errors across a sample of 30 review projects, averaging 200,000 errors per review, with 97% of reports under MiFIR/EMIR contain inaccuracies. These errors expose huge gaps for market abuse and systemic risk monitoring.
- Trade & Transaction
- ACA News
On January 26, 2022, the SEC voted to propose amendments to Form PF. The Proposed Rule is designed to enhance the data aggregated through private fund reporting. In our most recent blog, we break down the potential impacts of the proposal and what your firm needs to know.
Ahead of the impending change to the European short selling reporting threshold from 0.2% to 0.1% on the 31 January 2022, ESMA has reminded firms on reporting positions of more than 0.1% held over the transition period. Learn more about the changes:
Marie Luchet has joined the firm as Managing Director of ESG, heading up the practice’s strategy and vision for Europe.
ACA’s Connected Black Professionals Employee Resource Group is proud to continue this dialogue within ACA to foster and promote the talents and strengths of our black employees.
ACA Group awarded Best Legal, Compliance and Regulatory Advisory firm at The Drawdown Awards 2022. These awards celebrate excellence and innovation within private capital fund operations.
Using proprietary data ACA collected over the past few months, our experts will explain the current state of the cyber insurance market, walk through how policies work, and provide key considerations for whether and how to obtain insurance.
The role of the Money Laundering Reporting Officer (MLRO) is a mandatory position in all firms in the Financial Services Industry. This reflects the statutory objective that the Regulator(s) have for ensuring that firms behave with “Integrity”, particularly relating to financial crime prevention. The MLRO therefore plays a significant role in assisting Senior management to ensure that systems and controls relating to anti-money laundering (AML) and countering the risk of terrorist financing (CTF) are appropriate and effective. This course provides practical advice and guidance on the responsibilities of the MLRO, what is expected by the Regulators, both of the Senior Management and the MLRO, and how those responsibilities can be achieved. It should be noted that attendance at this course does assume a good knowledge of the UK’s AML/CTF regulations.