How We Partner with Clients
At CORE-CCO, we understand and appreciate that client relationships are paramount. We provide a consistent team who learns and knows our clients’ businesses intimately and on whom clients can quickly call whenever needed. We want our clients to confidently rely on their CORE-CCO partners as an integral part of their compliance team. We work exclusively with a select group of quality private fund and investment management firms and selectively add clients whose business and culture are a good fit with CORE-CCO’s, in order to help ensure a mutually beneficial long-term relationship.
We design a customized package of services for each client based on the needs of the client and consider each firm’s size and type of business, registration status, risks, conflicts, culture and preferences . Our services are tailored to include each of the following, or others, to fit the specific needs of clients.
Compliance Program Design and Administration
CORE-CCO seeks to ask the right questions, listen, learn and understand each client’s unique business thoroughly, in order to design and implement a comprehensive risk-based compliance program that complies with the Investment Advisers Act and other regulatory requirements, while being pragmatic and fitting the firm’s business environment. Design and implementation of the compliance program includes a customized Compliance Manual and Code of Ethics, policies, procedures, controls and disclosures.
In addition to designing an effective compliance program, clients can engage the CORE-CCO team as an extension of their staff to administer the compliance program, including maintaining a compliance calendar and checklists of required activities. We complete required compliance tasks, reviews, and monitoring and draft and maintain compliance documentation as contemplated under clients’ compliance policies and procedures.
Code of Ethics Administration
CORE-CCO can fully administer your Code of Ethics reporting, including personal securities reporting, outside business activities, gifts and entertainment, and political contributions. CORE-CCO reviews all information submitted or reported by employees, monitors for potential conflicts or issues, provides recommendations to the CCO regarding pre-approval requests, monitors for potential unreported activity, ensures completion of all required employee reporting, maintains ongoing documentation, and reports any issues to the CCO. We offer an electronic reporting system that enables broker feeds, automated compliance rules and monitoring, and electronic reporting and certifications by employees. We also offer electronic reporting forms and other solutions for employee reporting, based on our clients’ needs and preferences.
Annual Compliance Reviews
CORE-CCO 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.
Most third-party annual compliance reviews just scratch the surface of a firm’s business and primarily cover compliance tasks, regulatory filings and code of ethics reporting. Such 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 ensure that we are focusing on those areas that the SEC will cover, ensuring clients are well prepared for such scrutiny.
CORE-CCO provides regulatory compliance training for Chief Compliance Officers and client staff. As regulatory and compliance experts, our team is in a unique position to offer expertise, insights and instruction on regulatory and compliance requirements, regulatory developments and the implications for firm operations and activities, as well as SEC examination and enforcement findings. Training programs including in-person sessions, video vignettes, as well as online and electronic training modules.
AML/KYC Program Administration
Anti-money laundering, anti-bribery, anti-corruption and other financial crimes regulations are constantly evolving in the United States and around the world. With AML and sanctions specialists as part of our team, CORE-CCO offers full design and administration of client AML/KYC programs, including customized risk-based policies, procedures and training, customer identification, initial and ongoing investor screening, reporting and remediation. We assist clients in drafting FCPA and anti-bribery/anti-corruption policies and procedures and can also provide portfolio company, vendor and service provider sanctions screening and due diligence.
The CORE-CCO team works together with clients to analyze the firm’s activities, clients, investors and assets in order to determine registration and reporting requirements. We work alongside clients from inception to prepare initial registration documents and facilitate the registration process. In addition, CORE-CCO can administer the IARD and EDGAR reporting process for clients as well as relevant regulatory filings, including Form ADV, Form PF, Form D, Blue Sky filings, Form 13F, Form 13H, Schedules 13D or 13G, CFTC exemptions and filing and others as needed.
Regulatory Examination Support
It is our goal to work together with clients from the beginning of our relationship, throughout each activity we undertake over the life of the engagement, to prepare you to successfully navigate an eventual SEC or other regulatory examination. When clients do ultimately get the call from the SEC, they do so confidently because their CORE-CCO team has successfully prepared them. Our CORE-CCO team works alongside clients throughout the entire examination process to provide the resources, support, guidance, and expertise that is needed to successfully manage and conclude the examination and respond to any issues identified in subsequent communications.
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-CCO Exam Playbook.