ACA 2017 Fund Manager Compliance Survey Shows Continued SEC Focus on Compliance, Conflicts of Interest and Fees, and Illustrates Common Measures to Protect MNPI (Part One of Two)

The findings of the 2017 Alternative Fund Manager Compliance Survey by ACA Compliance Group (ACA) were discussed in a recent webinar by Danielle Joseph and Tessa Carbone, director and principal consultant, respectively, at ACA. This article, the first in a two-part series, covers the portions of the Survey that consider the frequency of SEC examinations and the topics they cover, as well as the pervasiveness of adviser efforts to protect material nonpublic information, including through the use of restricted lists and expert networks. The second installment will discuss common fee and expense-allocation practices by managers, along with manager efforts to comply with the recent business-continuity and transition-planning requirements promulgated by the SEC. See our two-part coverage of ACA’s 2016 Compliance Survey: “SEC Exams; Compliance Staffing and Budgeting; Annual and Ongoing Compliance Reviews; and AML/Sanctions Compliance” (Jan. 19, 2017); and “Custody; Fee Policies and Arrangements; Safeguarding of Assets; and Personal Trading” (Feb. 2, 2017).

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