Many private fund managers, including hedge and private equity fund managers, have fortified their compliance programs in response to increased regulatory scrutiny in recent years. Cipperman Compliance Services (CCS) recently issued the results of its 3rd Annual C-Suite Survey, which provides a snapshot of the current status of the compliance programs of hedge funds and other financial firms in light of this scrutiny. Among the results captured in the survey concerning hedge fund managers are the pervasiveness of dual-hatting
of chief compliance officers; the surprisingly small percentage of hedge funds that have been examined by the SEC in recent years; the significant percentage of hedge fund managers that have failed to perform their required annual compliance reviews; and the sizable amount of revenue that managers have allocated to compliance. This article analyzes these and other key findings from the survey. For additional commentary from CCS founder Todd Cipperman, see our three-part series on the simultaneous management of hedge funds and alternative mutual funds following the same strategy: “Investment Allocation Conflicts
” (Apr. 2, 2015); “Operational Conflicts
” (Apr. 9, 2015); and “How to Mitigate Conflicts
” (Apr. 16, 2015). For more on hedge fund compliance programs, see “SEC Chief of Staff Shares Fifteen-Step Plan for Adjusting to Compliance Responsibilities
” (May 26, 2016); and “RCA Compliance, Risk and Enforcement Symposium Highlights Methods for Hedge Fund Managers to Upgrade Compliance Programs
” (Jan. 14, 2016).