HRL provides a variety of service options for our clients.
Web-based Compliance Tool
comport365® is a software application which introduces very significant efficiencies to your firm’s compliance program. Designed for investment advisers and private funds, this compliance tool is utilized by firms ranging in size from $200 million to $17 billion in assets under management. This versatile web-based tool captures and monitors compliance events ranging from procedure testing and office inspections to meetings and training programs. comport365® provides a venue for the compliance team and line of business professionals to monitor and communicate about compliance matters. CCOs find comport365® to be an invaluable resource in the assessment and allocation of compliance capital. comport365® significantly supports the annual compliance review for advisers, as all records pertaining to compliance activities, including regulatory filings, compliance testing, recommendations, and resolution actions are consolidated within the tool.
In spite of the voluminous guidance and rule promulgation, ‘in the moment’ compliance inquiries are often a fact of life for SEC registrants. Client inquiries are fielded with a 24-hour response turn and billed at a predetermined hourly rate. Additionally, on-call services can be used in lieu of the project engagement format.
Compliance Risk Assessment (Gap Analysis)
Business and regulatory evolution can overtake even the most diligent CCO. Clients are provided with HRL’s perspective on the current compliance risk profile presented by the firm. In contrast to the mock audit, this service offering places a significant reliance upon client attestation and related risk management documentation pursuant to the firm’s internal control testing apparatus.
SEC Mock Audit
Broadway actors do it, the Navy Seal Team does it … and your firm can do it too. A dress rehearsal for the SEC examiner is the best preparation for your firm. HRL reviews all primary compliance documentation for congruence with the deployed business model and to ascertain compliance with the regulatory regime as represented by the firm’s functional regulators. Findings and recommendations reports are delivered in writing or orally. HRL is available to assist clients in deficiency and gap remediation as necessary.
Compliance Policies and Procedures Drafting
HRL offers customized policy and procedure drafting services to meet regulatory requirements. We have worked with start-up and seasoned advisers in building compliance policies from the ground up, as well as firms seeking to expand and/or overhaul existing programs. Investment advisory practice areas of import in a compliance program and procedure program include: role and activities of the Chief Compliance Officer, portfolio management processes; trading practices; personal trading and conduct of advisory persons; public disclosures, marketing material, and solicitation arrangements; safeguarding of clients assets, information and records; creation and maintenance of books and records; portfolio valuation and fee assessment practices; third party arrangements; and business continuity plans.
Investment Adviser Registration and Transition Services
HRL provides start-up services for newly formed investment advisers. Deliverables include Form ADV preparation and filing, policy and procedure development, internal control development, and related services to help firms meet regulatory requirements as they grow their business.
HRL also serves Exempt Reporting Advisers when transitioning to full adviser registration status. Services include Form ADV application and compliance program services.
Investment Adviser Compliance Program Implementation
HRL will implement initial audit/assessment recommendations and/or provide ongoing implementation of the enterprise compliance policy, procedure and internal control protocol. Ongoing implementation generally will entail scheduled onsite inspections and ongoing remote testing and client engagement and will be concluded at the close of the fiscal year with preparation and presentation of the adviser annual review report pursuant to SEC Rule 206(4)-7 requirements.
Cybersecurity and IT Risk Assessment
The Cybersecurity and IT Risk Assessment is intended to identify security risk sets attendant to the technology infrastructure and related risk-based security architecture as currently implemented by the investment adviser and private fund company. The Assessment results in a gap analysis which overlays the adviser’s IT infrastructure and related risk-based cybersecurity architecture with best in breed and/or regulatory mandated applications and risk mitigation strategies.
HRL offers customized training solutions to help clients nurture a compliant culture. Services and programs include:
- Annual compliance meetings
- Compliance training
- Regulatory examination preparedness training
- Audit findings and solution implementation training
- Product-specific education