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Compliance Corner

Welcome to Compliance Corner! ICSGroup will bring you monthly updates on regulatory trends and issues affecting investment advisors, particularly the issues that are most relevant to advisors of PE funds. Our goal is to help NAIC member firms develop and implement robust compliance programs that meet regulatory requirements and institutional investor expectations. We hope you find this information helpful and welcome your feedback. – Medina Jett, President, ICSGroup

A Strong Ethics Culture:  How Does Your Firm Rate?

A Strong Ethics Culture: How Does Your Firm Rate?

Assessing your firm’s ethics culture is the first step in developing and maintaining a strong ethics culture and, ultimately, to earning investors’ trust in your firm. In remarks from the 2016 FINRA Annual Conference, Chairman and CEO of FINRA, Richard Ketchum stated: “Having spent nearly four decades regulating the securities industry, and spending some time with a firm, I can say unequivocally that firm culture has a profound influence on how a securities firm conducts its business. I can’t count the number of times throughout my career where a culture that doesn’t value ethical behavior has led to compliance failures…
Securities Regulatory Outlook for 2017

Securities Regulatory Outlook for 2017

With 868 enforcement actions brought by the SEC, 2016 was a year of increased regulations and record enforcement actions against Investment Advisors/Investment Companies and Broker Dealers. More than $4 billion in disgorgement and penalties were assessed by the SEC and $145 million in fines and $41 million in restitution by FINRA. Promises of deregulation and a new administration in the White House raises the question: What will 2017 bring? From the Regulators FINRA On January 5, 2017, FINRA released its Regulatory and Examination Priorities letter highlighting areas FINRA will focus on in 2017. The focus areas are: High-Risk and Recidivist…
Department of Labor’s Intial Guidance on Fiduciary Rule

Department of Labor’s Intial Guidance on Fiduciary Rule

About our Contributors ICS Group is a regulatory compliance consulting firm specializing in providing compliance support to the financial services and insurance industries. We help our clients comply with regulatory requirements and industry standards. Our clients include: registered investment advisers, private equity funds, hedge funds, mutual funds, broker-dealers, insurance companies and state pension plans. Our team of highly experienced compliance professionals know from first-hand experience what regulators are looking for, the industry standards that apply, and how to develop and implement cost-effective business-oriented solutions. On October 27, 2016, the U.S. Department of Labor (“DOL”) released initial guidance primarily addressing the…
High Integrity Matters

High Integrity Matters

About our Contributors ICS Group is a regulatory compliance consulting firm specializing in providing compliance support to the financial services and insurance industries. We help our clients comply with regulatory requirements and industry standards. Our clients include: registered investment advisers, private equity funds, hedge funds, mutual funds, broker-dealers, insurance companies and state pension plans. Our team of highly experienced compliance professionals know from first-hand experience what regulators are looking for, the industry standards that apply, and how to develop and implement cost-effective business-oriented solutions. Despite mounting regulations, pressure on corporate leadership to run a compliant and ethical organization, and headline-making…
Operational Due Diligence  –  Part 3 of a 3-Part Series

Operational Due Diligence – Part 3 of a 3-Part Series

About our Contributors ICS Group is a regulatory compliance consulting firm specializing in providing compliance support to the financial services and insurance industries. We help our clients comply with regulatory requirements and industry standards. Our clients include: registered investment advisers, private equity funds, hedge funds, mutual funds, broker-dealers, insurance companies and state pension plans. Our team of highly experienced compliance professionals know from first-hand experience what regulators are looking for, the industry standards that apply, and how to develop and implement cost-effective business-oriented solutions. Operational Due Diligence (“ODD”) has grown in importance significantly for institutional investors looking to invest in…
SEC Amends Recordkeeping Rules

SEC Amends Recordkeeping Rules

About our Contributors ICS Group is a regulatory compliance consulting firm specializing in providing compliance support to the financial services and insurance industries. We help our clients comply with regulatory requirements and industry standards. Our clients include: registered investment advisers, private equity funds, hedge funds, mutual funds, broker-dealers, insurance companies and state pension plans. Our team of highly experienced compliance professionals know from first-hand experience what regulators are looking for, the industry standards that apply, and how to develop and implement cost-effective business-oriented solutions. On August 25, 2016, the Securities and Exchange Commission (“SEC”) adopted amendments to the Investment Advisers…
Proposed Regulation AT: Has the CFTC Gone Too Far?

Proposed Regulation AT: Has the CFTC Gone Too Far?

The Commodity Futures Trading Commission (“CFTC”) has recently caused quite a flurry among automated traders with its proposed Regulation Automated Trading (“Regulation AT”). The days of pit trading are long gone. Automated trades involving algorithms now make up a substantial portion of U.S. markets. Trading disruptions, unfortunately, have steadily increased as the use of automated trading has risen.
Business Continuity Plans

Business Continuity Plans

Although business continuity plans (“BCPs”) have been an SEC expectation, on June 28, 2016 the Securities and Exchange Commission (“SEC”) proposed a rule that would require all SEC registered investment advisers to adopt and implement a business continuity and transition plan.
Effective Due Diligence of Sub-Advisers: A Fiduciary Duty  –  Part 2 of a 3-Part Series

Effective Due Diligence of Sub-Advisers: A Fiduciary Duty – Part 2 of a 3-Part Series

About our Contributors ICS Group is a regulatory compliance consulting firm specializing in providing compliance support to the financial services and insurance industries. We help our clients comply with regulatory requirements and industry standards. Our clients include: registered investment advisers, private equity funds, hedge funds, mutual funds, broker-dealers, insurance companies and state pension plans. Our team of highly experienced compliance professionals know from first-hand experience what regulators are looking for, the industry standards that apply, and how to develop and implement cost-effective business-oriented solutions. In Part 1 of ICSGroup’s Due Diligence Series, Managing Vendor Risks: Implementing an Effective Third-Party Due…
Must Private Equity Firms Register as Broker Dealers?

Must Private Equity Firms Register as Broker Dealers?

Does your firm routinely solicit investors and/or co-investors? Does it market its funds to endowments, pension funds and high net worth individuals? Does your firm advise companies on mergers and acquisitions and debt offerings? If your firm receives compensation for any of these services, then you could be engaging in broker-dealer activities for which registration as a broker-dealer is required.
Managing Vendor Risks: Implementing an Effective Third-Party Due Diligence Program – <i>Part 1 of a 3-Part Series</i>

Managing Vendor Risks: Implementing an Effective Third-Party Due Diligence Program – Part 1 of a 3-Part Series

Financial services firms are increasingly contracting with third-party service providers to perform activities related to their business functions and regulatory responsibilities.
Exclusively for NAIC Members: ICS Group Offers Complimentary Mock Exams

Exclusively for NAIC Members: ICS Group Offers Complimentary Mock Exams

The SEC expects to increase the number of investment adviser examinations in 2016. The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) is also increasing the number of examiners by almost 20% this year...

Founded in 2008, ICSGroup is a boutique compliance firm that provides regulatory compliance services to registered investment advisors, including advisors to private equity funds, hedge funds and fund of funds, banking institutions and insurance companies. Prior to starting ICSGroup, its founder, Medina Jett, served in senior compliance roles at several large financial services companies where, in spite of good values and a strong ethical culture, compliance was often at odds with business interests.

Medina envisioned an easier way to deliver compliance services. ICSGroup partners with its clients to create risk-appropriate compliance solutions, to integrate compliance procedures seamlessly into business practices, and to create a culture of employee engagement, while meeting regulatory expectations and enhancing investor confidence. ICSGroup is a minority and woman-owned business enterprise with offices in downtown Hartford, CT and downtown Manhattan.

Contact ICS Group

ICSGroup offers a variety of compliance services ranging from a la carte services to fully outsourcing the compliance function.