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Steelbridge Compliance Brochure


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Steelbridge Compliance Brochure

  2. 2. Perspective. Purpose. Practicality.The Steelbridge Di erenceSteelbridge Compliance is di erent from other compliance service providers.We are attorneys and CPAs with decades of combined operational experienceat leading fund organizations - not just outside service providers or formerpublic sector personnel.Steelbridge Compliance is focused on "real world" solutions tailored to yourspecific business and needs - not one-size-fits-all best practices, and noexcessive and irrelevant inquiries.Steelbridge Compliance is sensitive to minimizing disruption and expense,while adding value and e ciency to your business. That is why services arestrictly flat-fee.Steelbridge Compliance maintains strong relationships with regulators,investment advisors, investors, industry trade groups and other industryservice providers, and has a deep understanding of the compliancerequirements required by each constituent group.2.8 WWW.STEEBRIDGECOMPLIANCE.COM
  3. 3. Product and Services O erings The SEC requires it. Investors want it. Assessments & • Compliance Program Review. (Annual or Quarterly) Reviews • Tier 1: High level risk based assessment in light of requirements. • Tier 2: Assessment based on current policies and procedures and gap analysis. • Tier 3: Procedure creation and modification based on gaps. • Mock Audits and Exams. • Specialized Reviews. (Code of Ethics, Privacy, AML, other program components) • Specialized Testing of Processes and Internal Controls. The exemptions are now very narrow, and registration is likely required. Advisor • Registration, SEC and states. Registration & Filings • ADV Part I & Part II. • Filing Support, Federal and state. Do not let projects linger. Outsource them.Focused Services • Business Continuity and Disaster Recovery Planning/Testing. & Reviews • SEC/state Exam Support. • Restricted Securities Reviews and Legend Updating. • Book and Record Compilation and Organization. • Onsite and Offsite Compliance Training. 3.8 WWW.STEEBRIDGECOMPLIANCE.COM
  4. 4. The Dodd-Frank Act of 2010 may bethe most sweeping financial regulatory reform since the Great Depression. Most advisors have been relying on the fifteen or fewer client exemption to registration. It is gone. Registered advisors must have annual written compliance reviews. The SEC now wants to see fund trading positions, side letters, and all uses of leverage. Business Continuity — what happens if the largest investor leaves? 4.8 WWW.STEEBRIDGECOMPLIANCE.COM
  5. 5. Dear Advisor:The Dodd-Frank Act requires most advisors of private equity and hedge funds toregister with the SEC or the states, and sets a deadline of one year from its enactmenton July 21, 2010 to do so. Advisors should be wary of that deadline though.Currently, it can take upwards of two months for the SEC to approve an advisorsregistration. Next year, an expected flood of new registrations is likely to create abacklog that could extend this timeline. The situation could be even worse foradvisors registering with the states, whose regulatory agencies are generally morelightly sta ed and funded.An advisor that is not appropriately registered with the SEC or states by thedeadline, even during the pendency of its application, cannot charge fees.Advisors should, therefore, begin the process as soon as possible, including byestablishing and improving their compliance programs. Please let me know ifSteelbridge Compliance can be of help. I also invite you to subscribe to our newsfeed for information on new rulemaking and upcoming events regards,D. NiknejadManaging DirectorSteelbridge Compliance LLC(214) 960.4811dn@steelbridgecompliance.com5.8 WWW.STEEBRIDGECOMPLIANCE.COM
  6. 6. “An integrated Compliance Program is robust. It augments your business, while reducing risks and enhancing your firm’s reputation.” ROBUST COMPLIANCE PROGRAMAttract More Investor Money Keep the Money You EarnThe Dodd-Frank Act is expected to raise the Avoid State and SEC interference and fines.investor qualification thresholds, limiting Shorten SEC inspections and reducepools to high net worth investors and business distraction.institutional investors. Low cost, outsourced compliance functionsLarge and institutional investors demand require fewer internal hires.strong compliance procedures and backtesting, regardless of the SEC or states. ENHANCE YOUR REPUTATION IN THE MARKETPLACE 6.8 WWW.STEEBRIDGECOMPLIANCE.COM
  7. 7. Case Studies. Establishing Your Business & Brand. Who New or newly registered investment advisor. Goals Ensure meeting basic compliance requirements. Special • $30m AUM, traditional long-short equity pooled vehicle with some minorCircumstances separate accounts. • Lightly staffed, without resources to dedicate to compliance issues. Solutions Provision of tailored compliance manual. A low-cost, high level ‘Tier 1’ assessment of Provided current policies, and recommendations for improvement. Registration with state. Building Your Business & Brand. Who Established, SEC registered investment advisor. Goals Determine if compliance program is robust enough for firm’s growth and new strategies. Special • $100m AUM, two or more pooled vehicles with sizable separate accounts. MultipleCircumstances asset classes. Initiatives to attract ERISA money and establish an offshore vehicle. • Some compliance staff, but generally dedicated to day-to-day transactional issues. Solutions A detailed ‘Tier 2’ assessment of compliance policies and procedures. Update Provided compliance manual for new initiatives, and review agreements for authority in light of possible “strategy drift”. Gap analysis related to ERISA issues and offshore investors. Determine whether rule changes require re-registration with state. Address legends on restricted securities now eligible for unrestricted trading. Protecting Your Business & Brand. Who Large, sophisticated SEC registered investment advisor. Goals Ensure meeting compliance requirements of a complex advisor, and that programs and procedures optimize profitability. Clear lingering compliance initiatives o of plate. Special • $2B AUM, multiple on-shore and offshore pooled investment vehicles, includingCircumstances principal accounts. Numerous asset classes and investor types, including institutional investors. Frequent trading in public companies, and several employee directorships. • Significant but stretched compliance staff. Multiple third-party service providers performing many functions touching compliance. Solutions Focused ‘Tier 3’ review of compliance policies and procedures. Gap analysis, Provided assessment, findings and a road map for implementation of program to address UBTI/ECI tax issues, principal trading and trade related filings, and conflicts issues. Coordination with third party service providers to organize books and records in anticipation of SEC exam. 7.8 WWW.STEEBRIDGECOMPLIANCE.COM