ACA Briefing: Regulatory Responses to Coronavirus Pandemic and Best Practices for Business Continuity and Compliance

As the coronavirus pandemic continues to spread social and financial turmoil, private fund advisers must adapt to rapidly changing – and potentially unforeseen – circumstances, including the possibility that they will have to operate with distributed workforces for a considerable time and that large portions of their staffs may be affected simultaneously. Although regulators are offering relief from certain filing and other obligations, advisers must nevertheless attempt to continue their operations in compliance with the existing regime. A recent ACA Compliance Group (ACA) seminar discussed the steps that regulators are taking to address the crisis and how advisers can enhance their operational resiliency while fulfilling their compliance duties. The program featured Carlo di Florio, partner and global chief services officer at ACA; Laurin Blumenthal Kleiman, partner at Sidley Austin; and Michael Pappacena, partner at ACA. This article discusses the key takeaways from the presentation. For additional insights from di Florio and Pappacena, see our two-part series on safeguards for proper disposal of hardware: “Risks and Examiner Expectations” (Mar. 19, 2020); and “Effective Inventories, Policies and Due Diligence” (Mar. 26, 2020).

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