For funds that outsource their back office activities, such as fund accounting and administration, transfer agency, distribution or use sub-advisers to manage the Fund, Rule 38a-1 requires the Fund CCO to conduct oversight of the service provider’s compliance program, including its policies and procedures.
Outsourced Fund service provider compliance oversight has become increasingly important as Fund Boards, CCOs and advisers are required to demonstrate the due diligence undertaken before and after the selection process.
Cordium will conduct regulatory and operational due diligence on the Fund’s third party service providers to ensure that the Fund CCO has the tools, information and insights they require to comply with their oversight obligations under Rule 38a-1.
We have experience with a large number of external fund service providers, their operations and compliance programs. Also, we can undertake a comprehensive periodic fund sub-adviser due diligence review for the Fund Board or the CCO.