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

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

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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

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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.

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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.

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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.

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Form ADV Danger Zones

March 8, 2016 – March 30 is the deadline for registered investment advisory (“RIA”) firms to file Form ADV annual updating amendments. Executives, including CCOs, who have intentionally or inadvertently misstated or failed to disclose material information on their Form ADV have been personally fined and/or barred from the financial industry. As NAIC’s Compliance Partner we’re here to help you avoid regulatory blemishes.

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Don’t Get Charged with Misallocating Fees and Expenses

February 9, 2016 – Over the past several years, the Securities and Exchange Commission (“SEC”) has been increasingly focused on the fee and expense practices of private equity firms. In 2016, the SEC will continue its focus on whether fee arrangements are in the best interest of the investor and if adequate disclosures are made to investors about fees and expenses.

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Compliance Hot Topics for 2016

January 12, 2016 – For our Compliance Corner inaugural issue, we are highlighting some of the compliance hot topics that will be front and center for the SEC. We believe this list, while not exhaustive, addresses the high-risk practice areas and major initiatives that can help you build an effective compliance program.

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About ICSGroup

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 ICSGroup

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

Complicance Corner

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