We understand and appreciate that client relationships are paramount. We provide a consistent team who learns and knows our clients’ businesses deeply and on whom clients can quickly call whenever needed. Our clients confidently rely on their core partners as an integral part of their compliance team. We work exclusively with a select group of quality private funds and institutional managers. We selectively add clients whose business and culture are a good fit with core’s, in order to help ensure a mutually beneficial long-term relationship.
Core seeks to ask the right questions, listen, learn and understand each client’s unique business thoroughly as we build a comprehensive risk-based compliance program that satisfies regulatory requirements, but is also pragmatic and fits the firm’s business. The compliance program includes a customized Compliance Manual and Code of Ethics, policies, procedures, controls and disclosures.
You can engage core as an integral part of your compliance team to administer the compliance program, including maintaining a compliance calendar and checklists of required activities. The core team engages with your team regularly through in-person and virtual compliance meetings and plays an integral role in managing and completing requisite compliance tasks and responsibilities.
Clients can engage the core team to review marketing materials and investor communications and monitor email, social media, and other electronic communications. You can further engage our team to conduct strategic monitoring and surveillance of portfolio activity, trading, best executive, proxy voting, service provider due diligence, and other activities. Core conducts other bespoke review projects to address specific risk and focus areas, as needed.
Core conducts comprehensive independent reviews of clients’ compliance program, policies and procedures, as required by Rule 206(4)-7 of the Investment Advisers Act, which cover all functional areas of the firm’s business, utilizing document reviews, interviews with business personnel, monitoring and forensic testing. An inclusive summary of the annual review exercise allows core to work collaboratively with clients to confirm, implement and document recommendations and their resolution.
Many third-party annual compliance reviews just scratch the surface of a firm’s business and primarily cover compliance tasks, regulatory filings, code of ethics reporting and some basic standardized testing. However, a limited focus annual review leaves firms exposed to areas that the SEC will undoubtedly focus on during examinations. Core utilizes comprehensive compliance modules to focus on specific areas that the SEC will cover in private fund exams, helping to ensure clients are well prepared for such scrutiny.
Anti-money laundering, anti-bribery, anti-corruption and other financial crimes regulations are constantly evolving in the United States and around the world. Core’s team of AML and sanctions specialists design and administer a risk-based AML/KYC program, which includes customized risk-based policies and procedures, AML training, customer identification, due diligence, sanctions screening, continuous monitoring, reporting, and remediation. We assist clients in drafting FCPA and anti-bribery/anti-corruption policies and procedures. We provide portfolio company, founder, vendor, and service provider due diligence and sanctions screening.
The core team works together with clients to analyze the firm’s investment activities, clients, investors, and assets to determine registration and reporting requirements and available exemptions. We work together with clients and outside counsel to prepare initial registration documents and facilitate the registration process. In addition, core administers the IARD and EDGAR reporting system for clients and manages regulatory filings, including Form ADV, Form PF, Form D, Blue Sky, Form 13F, Form 13H, Schedules 13D or 13G, Form N-PX, Form SHO, CFTC exemptions, and other filings, in consultation with outside counsel, as needed.
Core works together with clients from the beginning of our relationship, and throughout our engagement, to prepare them for a successful SEC or regulatory examination. When clients do ultimately get the call from the SEC, they can do so confidently because their core team has successfully prepared them. The core team works alongside clients throughout the entire examination process to provide resources, support, and expert guidance to successfully manage and conclude the exam and respond to any deficiencies. As former regulators and compliance experts, our team has been through hundreds of examinations on both sides of the table. We know what to expect and how to successfully pass an exam.
We invite you to contact us to discuss your needs in preparing for or managing a regulatory examination and request a copy of our full core Exam Playbook.
Core works with clients to review fund governing documents, financial and performance reporting, side letters, and other key documentation, and interviews key employees and stakeholders to assess readiness for the private fund rules. Based on such review and analysis, core will provide recommendations, reporting templates, performance calculation models, and other tools as needed to ensure that the firm is prepared to comply with the applicable rules by requisite compliance dates.
Core’s team of SEC and private fund experts are well equipped to provide other bespoke projects and services as needed to large managers or those who primarily manage compliance in-house. Projects may include comprehensive review and testing on high-risk or specific focus areas. Customized policy design, revision or revamp to address new business lines, products or activities. Cybersecurity risk management administration and assessment, service provider or vendor due diligence, and other projects as needed.
