Compliance Evaluations/Mock Audits

Compliance evaluation projects are designed for advisers looking for a comprehensive compliance infrastructure review of theirShadow-only obligations under the Investment Advisers Act of 1940 and other applicable regulations.

The project team will perform a critical review of your internal compliance policies, procedures and existing business practices and provide feedback on our findings along with practical recommendations. Part of our feedback will include suggestions on how to simplify and streamline your procedures. The review can also be done in a “mock exam” format to mimic a typical SEC exam (where Cordium plays the role as the examiner and the scope of the project is more limited).

The scope of a compliance evaluation project will be determined in collaboration with each client, but may include:

Review of procedures and actual practices related to:

  • Record-keeping
  • Form ADV disclosure, delivery and updates
  • Code of ethics / personal securities trading
  • Annual compliance review
  • Review of fiduciary obligations
  • Custody
  • Insider trading
  • Money movement controls
  • Proxy voting
  • General employee responsibilities
  • Soft dollar usage
  • Privacy policies
  • Aggregation/allocation practices
  • Email retention and review
  • Best execution review process
  • Marketing materials
  • Public website use and Reg D issues

Review of various disclosure documents for consistency among such documents and with actual business operations

Review of private fund specific issues, such as:

  • Investor eligibility
  • AML procedures, etc.

In addition, the project team will help you (as applicable to certain projects):

  • Modify procedures where there may be deficiencies
  • Revise, modify and/or expand your written compliance procedures if needed
  • Develop a detailed compliance calendar that is unique to your business
  • Develop and implement a compliance training program for your employees