Seward & Kissel Regulatory Compliance (SKRC) offers a broad range of compliance services to investment advisers.  SKRC brings a practical, tailored approach to each compliance engagement based on our extensive legal, governmental and regulatory experience coupled with the real world knowledge gathered from our large network of relationships within the financial services space.  Please click below to learn more.

SKRC offers comprehensive compliance consulting services, from the compliance help needed during the formation/start-up phase of your business to the ongoing compliance consulting and support required as your firm grows and matures. SKRC’s compliance consulting services include annual compliance review, annual compliance training, compliance manual, compliance calendar, interim reviews and testing, Form ADV updates and day to day advice. Our consulting services are available on tailored fixed-fee arrangements.
SKRC represents investment advisers in SEC examinations, providing advice throughout the examination process, including the introductory phone call with SEC examiners, initial and supplemental document requests, opening firm presentation, the on-site exam, interview preparation and deficiency letter response.
SKRC advises entities in the event of a security breach resulting in authorized access to personal information. Our services include a 50-state chart of security breach notification laws covering topics including notification to residents and governmental authorities, key definitions, and available exemptions.

Seward & Kissel publishes alerts and memoranda that highlight new regulatory and industry developments. These publications can assist you in staying informed on matters affecting investment advisers and their advisory clients. Click here to see our recent publications.

SKRC conducts mock audits that are designed to prepare you for an SEC exam. Drawing from our deep experience representing investment advisers in SEC exams, investigations and monitorships, our mock audits help identify red flags and regulatory risk areas. We review relevant portions of your books and records and conduct in-person interviews of key personnel in an effort to replicate the SEC exam experience.

In an interview with The Hedge Fund Law Report, David Tang, counsel at Seward & Kissel LLP, provided his thoughts on mock audits, their prevalence in the industry and best practices for advisers to use mock audits to prepare for an SEC examination.

SKRC provides training on insider trading and material nonpublic information (“MNPI”). Topics covered include current case law and legal developments on insider trading, best practices in MNPI monitoring, policies and procedures with respect to expert network and other consultants, meetings with company management, sell-side and buy-side communications, electronic communications review, trade surveillance and dos and don’ts when using e-mail and other electronic messaging.

SKRC offers a chart of state beneficial ownership reporting requirements for public companies engaged in various gaming activities in the United States and certain other jurisdictions. This chart is offered free to our investment adviser clients and available for purchase by non-clients ($1,500).

SKRC offers annual compliance reviews, including documentation reviews and on-site meetings, designed to help advisers meet their obligation under Rule 206(4)-7 of the Investment Advisers Act to review, no less than annually, the adequacy of the adviser’s policies and procedures and the effectiveness of their implementation.
SKRC offers annual compliance trainings for investment advisers. Our compliance trainings are designed to address key policies and procedures, conflicts of interest, and risk areas, including insider trading, personal trading, gifts and business entertainment, outside business activities, political contributions, social media, electronic communications, and cybersecurity.

SKRC offers an online subscription service, providing access to compliance tools and resources that can assist investment advisers with their registration and ongoing compliance obligations. The documents available through the subscription service are user-friendly and can be tailored for any advisory business. In many cases, they provide a step-by-step process to assist you in completing the required document. The subscription service is offered free to our investment adviser clients and is available for purchase by non-clients.

Click here to learn more about the subscription service.

More Information

For more information on any of SKRC’s services, please contact your primary attorney in Seward & Kissel’s Investment Management Group or David Tang at tang@sewkis.com or (212) 574-1260.