Greetings! It’s an ever changing landscape in the world of hedge fund compliance — so I am excited about bringing some information to you that might help you through the day. If there are topics that you wish to learn more about — please send them along via the website! Thanks for visiting and I [...]
More and more asset managers and broker dealers are turning to their board of directors and special committees to address conflict and risk issues. A disciplined process, inclusive of specific mission statement, regular and documented meetings with formal agendas, inclusive of overview and analysis of operational tests, have multiple benefits, inclusive of: - oversight and [...]
By now we are all familiar with the reasons why all firm should have workable business continuity and disaster recovery protocal in place. But — along with many things — it is one of the easier elements of the risk management procedures to overlook. In a 2003 speech Disaster Recovery and Business Continuity PlanningDisaster Recovery [...]
Right on the tails of their new rule 206(4)-8 (“the Anti-Fraud Rule”), prohibiting advisors to pooled investment vehicles, registered and unregistered funds, from making ambiguous statements or, deceiving their investors or prospective investors, the SEC filed one new claim and found a fugitive of an old one. Fine additions to their hall of fame:Sentinel – On Monday, [...]
With September just around the corner – it is time to re-focus on the state of your compliance program. By now the following words are etched into the hearts and minds of all Chief Compliance Officers, but it still bears repeating: Rule 206(4)-7 [Investment Adviser Act] and rule 38a-1 [Investment Company Act] “require each investment company and [...]
Thanks to the ERISA requirements, Trustees of pension funds have a higher threshold for the selection of investment managers then the standard investor. Most Trust Deeds will incorporate the regulatory and case law requirements for the review of the investment manager. A sample set of criteria may resemble this: - The manager must be [...]
One of the harder aspects of a bullet proof compliance program is making sure that the policies regarding your fund’s operations are effective and will catch potential violations before the fact. Key to accomplishing this goal is taking a practical approach to compliance management and working with your business staff to make sure that there [...]
As the markets correct, some managers are finding that their investment theories are not measuring up as they had hoped. This past week a number of two quant funds reported significant losses year to date. What is strange about these returns is that a market neutral strategy is generally designed to weather market downturns and [...]
It’s usually the last to-do on your list. Long after the development of the policies and procedures, the compliance calendar, the audit and risk assessment - it’s still there waiting to be finalized and delivered – the training program. With good reason as it may be the hardest task of all. However, while creating a solid training program that [...]
It seems that with each hedge fund meltdown, comes an SEC investigation. In the latest installment, last week, SEC Chairman Christopher Cox announced that the agency was reviewing approximately 12 hedge funds with regards to the valuation of C.D.O. instruments. This is on the heals of the recent “near collapse” of the two Bear Stearns [...]
