ACA 2016 Compliance Survey Addresses Custody; Fee Policies and Arrangements; Safeguarding of Assets; and Personal Trading (Part Two of Two)

In its 2016 Alternative Fund Manager Compliance Survey, ACA Compliance Group (ACA) covered various issues pertinent to hedge fund and illiquid private fund managers. ACAs Brian Lattanzio, a senior compliance analyst and private equity associate, and Danielle Joseph, a senior principal consultant, discussed the survey results in a recent webinar. This article, the second in a two-part series, explores the survey findings concerning the custody of fund assets and certificated securities; procedures around and types of fees charged by illiquid fund managers; steps to safeguard assets; and personal trading. The first article summarized the surveys results pertaining to SEC examinations; compliance staffing and budgeting; compliance reviews, testing and training; and anti-money laundering and sanctions compliance. For additional insights from ACA experts, see Recommended Actions for Hedge Fund Managers in Light of SEC Enforcement Trends” (Oct. 22, 2015); and The SECs Broken Windows Approach: Compliance Resources, CCO Liability and Technology Concerns for Hedge Fund Managers (Part Two of Two)” (Oct. 1, 2015).

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