SEC Compliance Services for fund managers

Compliance programs should be designed to fit your unique risks

The SEC compliance landscape grows increasingly challenging for private fund managers as they face deeper scrutiny from regulators, along with a multitude of new SEC rule adoptions and proposals that significantly raise the bar for developing and managing a fund’s compliance program.

New SEC rule adoptions and proposals:

Revised investment adviser advertising rule

Private fund adviser rule proposal

Amendments to Form PF

Oversight over third-party service providers

ESG rule proposal

Cybersecurity rule proposal

Benefits of being prepared

Private fund managers who proactively maintain a compliance program that is resilient and effectively responds to the dynamic forces of the regulatory landscape will be best prepared for the closer regulatory scrutiny and resourcing demands that are on the horizon.

How can KPMG help

KPMG regulatory risk and compliance professionals include former regulators, supervisors, examiners, and compliance practitioners equipped to provide actionable advice to help you strategically address regulatory change. Our readiness review services include:

Business review: Assess firm’s business model, product offerings, marketing materials, regulatory filings, and existing policies and procedures to identify high-risk activities.

Data collection and analysis: Prepare an SEC-style document request list covering the major components of a compliance program in accordance with Rule 206 (4)-7 (the “Compliance Rule”) of the Advisers Act.

Interview and inquiry: Conduct targeted interviews, similar to an SEC Exam, to assess a firm’s understanding of its obligations under the Adviser’s Act and the culture of compliance.

Risk Assessment: Incorporate our understanding of your firm’s unique risks, recent guidance provided by the SEC, lessons learned from recent enforcement activity, and KPMG’s understanding of prevailing industry practices.

In-depth reviews of selected topics: Based on the initial risk assessment, KPMG may perform deeper-dive review procedures in areas mutually agreed upon as having higher inherent risk.

Final deliverable: Prepare a fully vetted, final report that outlines the scope of the review, procedures performed, and our observations and recommendations.