What is a Chief Compliance Officer (“ССО”)?

Rule 206(4)-7 of the Investment Advisers Act of 1940 (the “Advisers Act”) requires each SEC-registered investment adviser to designate a CCO to administer its compliance policies and procedures.

Similarly, pursuant to Rule 38(a)-1 of the Investment Company Act of 1940 (the “40 Act”), the Board of Trustees of a registered fund company must designate a Trust-level or Fund CCO to administer the Trust’s or Fund’s compliance program and oversee Fund service providers, including investment advisers, underwriters, administrators, and transfer agents.

The CCO serves as the point person for compliance oversight and 40 Act regulatory requirements, reporting directly to the Board to ensure a compliance program is in place to protect investors and that policies and procedures are current and aligned with applicable rules and regulations. The CCO also ensures the compliance program is tailored to Fund-specific business activities and risks and that the Fund practices follow the established policies and guidelines.

How can Nottingham help with your compliance needs?

Nottingham offers compliance services tailored to your needs.

These offerings include oversight of the following:

  • Training
  • Electronic communications review
  • Advertising, marketing practices, materials and related disclosures
  • Business continuity and disaster recovery plans and testing
  • Vendor management and service provider relationships
  • Obligations under the 40 Act, specific jurisdictional requirements
  • Relevant compliance issues, policies and practices, as appropriate, including assistance with regulatory examinations or investigations
  • Form ADV, Parts 1, 2A, 2B and 3 (Form CRS)
  • Written policies and procedures and Code of Ethics
  • Compliance calendar and risk assessment
  • Related entities and/or affiliations
  • Cybersecurity program and practices
  • Controls and testing program and apparatus, portfolio compliance
  • Conflicts of interest

Nottingham helps both new and existing investment advisory firms manage compliance.

For new firms, it assists with formation, SEC registration, and setting up a compliance program with ongoing oversight.
For existing firms, Nottingham offers consulting, program enhancements, outsourced CCO services, and technical solutions like portfolio compliance and liquidity risk tracking. Its team collaborates with internal personnel and senior management to ensure compliance with federal and state securities laws.

With extensive industry experience and expertise in fund administration, Nottingham delivers effective, high-quality, and cost-efficient compliance solutions.

What are the benefits of an outsourced CCO

or consulting relationship with Nottingham?

  • Experience and expertise
  • Cost effective
  • Independent and transparent assessment of existing compliance practices and policies
  • Continuous compliance program maintenance and oversight
  • Improved efficiency and use of internal resources
  • Avoid the dangers of not knowing what you don’t know

How do I get started?

A prospective Nottingham compliance relationship begins with a consultation regarding the firm’s current compliance program or the task of building a new program. Through this consultation, we can help you determine if outsourcing compliance services makes sense for your advisory firm and if so, what services would most effectively and economically benefit your business and address your needs.

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