ADVANCED

Ongoing Compliance Consulting Support

Advisers looking for proactive, hands-on compliance and operational support are best suited for our ongoing compliance support services. We can tailor the relationship depending on the size and complexity of your firm and your compliance needs. Additionally, you have the option of using Cordium as a resource in the case of a regulatory audit. In the US, we offer different levels of support so that you can choose the level that fits your business needs. Our team will work with you on a regular basis to handle many of your weekly, monthly, quarterly or annual compliance responsibilities (depending on the service level that suits your needs). Our goal is to support the CCO and allow the CCO to focus more time on their other responsibilities.

The scope of the engagement will be determined in collaboration with each client, but typical levels include:

  • Level 1 Support
    • ■ Administer 206(4)-7 annual compliance review
      ■ On-site time to review specified issues with CCO
      ■ Expansive forensic testing of compliance procedures and records;
      ■ Preparation and coordination of compliance inquiries with service providers;
      ■ Compliance interviews with staff
      ■ Compliance manual review and update
      ■ Annual compliance training for staff
      ■ Manage process of updating and filing Form ADV Part 1 and review and update Part 2 as needed
      ■ Reasonable phone and email support for miscellaneous questions
      ■ Approx 140-160 consulting hours per yearCordium can also assist with an optional audit preparation service and audit support services as needed.
  • Level 1 Lite
    • A similiar service as Level 1 above (although certain tasks require increased responsibilites on the client)
    • ■Reasonable phone and email support for miscellaneous questions
      ■Approx 70 consulting hours per year.
  • Level 2 Support
    • Level 2 consists of the same annual review services as Level 1 plus:
      ■ Quarterly review and testing of specific compliance areas
      ■ Audit preparation support services
      ■ Reasonable phone and email support for miscellaneous questions
      ■ Approx 175 to 220 consulting hours per year
  • Level 3 Support
    • Level 3 is our highest level of support and is based on a much more frequent interaction. It typically includes everything in Level 1 and 2 plus:
      ■ New employee start-up support
      ■ Pro-active audit support
      ■ Monthly compliance tasks and undertakings
      ■ Monthly compliance meetings with the CCO
      ■ As needed (i.e., daily) phone and email support
      ■ Approx 600 to 660 consulting hours per year
  • CFTC compliance support
    • Cordium offers varying levels of on-going support services for firms registered with the Commodity Futures Trading Commission (“CFTC”) as commodity pool operators (“CPOs”) and/or commodity trading advisors (“CTAs”). Such services may include assisting CPOs and CTAs with annual reports to be submitted to the National Futures Association (“NFA”), providing guidance with completing quarterly and annual filings to be made with the NFA (including Forms CPO-PQR and CTA-PR), and developing and maintaining a compliance infrastructure that conforms to applicable CFTC and NFA requirements. We can tailor a consulting relationship based upon your specific business needs.The scope of on-going CFTC compliance support services will be determined in collaboration with each client, but may include:
      ■ CPO/CTA Questionnaires and Firm & DR Information Questionnaires
      ■ Annual Registration Updates
      ■ Annual Review/Documentation of Self-Exam Checklist/Questionnaire & Attestation
      ■ Annual Review of NFA By-Law 1101 Compliance
      ■ Annual Review of Registration Status of Employees (Principals and Associated Persons)
      ■ Modification of compliance procedures to address CFTC/NFA issues
      ■ Annual NFA Ethics Training (including development of presentation/slides)
      ■ Consulting advice on CFTC/NFA questions and new regulatory developments
      ■ Registering/Listing additional (i) Associated Persons and/or Principals, and/or (ii) CPOs and/or CTAs (as needed during the course of the year)
      ■ NFA audit support