Private Fund - Compliance Launch Program

SCA has developed a compliance program specific to hedge fund, private equity and venture capital fund managers (“Private Fund Managers”) who are not registered with the SEC. This program is designed to address the need for internal controls and risk management processes in a manner that is less burdensome from a resource standpoint than a full SEC compliance program, while still achieving the primary benefits of such a program. Deliverables include a customized Written Compliance Manual, Code of Ethics and related forms and checklists.

The benefits of this program include:

• A higher degree of confidence that the Manager is meeting its fiduciary responsibilities to investors and complying with regulatory requirements that apply to all Private Fund Managers;
• Reduced risk that the Private Fund Manager will become the subject of a regulatory or investor legal proceeding and suffer the reputational damage that follows such actions;
• Additional assurances to potential investors; and
• Substantial reduction of the time and expense necessary to comply with SEC requirements in the event that the Private Fund Manager will be required to register in the future.

SCA’s programs are customized based upon the size, nature and complexity of the organization, its strategies and resources, as well as the objectives of the funds being managed. SCA utilizes guidance from the President’s Working Group for Asset Managers and the Managed Funds Association.

The following areas are generally addressed:

• Management and Internal Trading Controls;
• Responsibilities to Investors;
• Valuation of Portfolios;
• Risk Monitoring;
• Regulatory Controls;
• Brokerage Practices;
• Business Continuity and Disaster Recovery; and
• AML Practices.

SCA also offers compliance program implementation assistance, as well as ongoing testing and monitoring of compliance procedures. SCA also provides an inspection program for unregistered Private Fund Managers.