Compliance
The Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) requires that asset managers with between $25M and $100M assets under management register with either the state in which they maintain their principal place of business, or with the SEC. Furthermore, Dodd-Frank augmented SEC rule 206(4)-7 to require asset managers to have a defined compliance program, including:
- Designate a Chief Compliance Officer to be responsible for administering the compliance policy and procedures
- Design a compliance program, including written procedures reasonably designed to detect and prevent violations of the Adviser Act
- Review the compliance program on an annual basis
These new requirements will increase the time required to monitor and report on the fund’s activities, distracting the principals from working on transactions. Lamplighter can mitigate that distraction by designing a compliance policy that can be implemented and administered quickly and efficiently and acting as the administrator of the policy. We encourage our clients to implement these procedures as soon as possible – especially if fundraising is on the horizon as this is becoming an increasing hot point of due diligence for institutional investors.