ACA 2017 Fund Manager Compliance Survey Addresses SEC Exams and Practices Used to Mitigate Counterparty Risk (Part One of Two)

Compliance-focused surveys provide an opportunity for private fund advisers to benchmark their policies, procedures and practices against their industry peers. The findings of the 2017 Alternative Fund Manager Compliance Survey conducted by ACA Compliance Group (ACA) were discussed in a recent webinar by Colleen Marencik and Brian Lattanzio, director and consultant, respectively, at ACA. This article, the first in a two-part series, examines the survey’s findings with respect to recent SEC examinations, along with hedge fund trading and counterparty issues, including best execution; soft dollars; principal transactions and cross trades; dark pools; and trade errors. The second article will discuss the survey’s findings regarding investment allocation practices by private equity and real estate managers, including co-investments; cross transactions; best execution and fees; conflicts of interest; and valuation. See also our two-part coverage of ACA’s April 2017 fund manager compliance survey: “Continued SEC Focus on Compliance, Conflicts of Interest and Fees, and Common Measures to Protect MNPI” (Jun. 1, 2017); and “Variety in Expense Allocation Practices and Business Continuity Measures” (Jun. 8, 2017).

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