Foreside's 38a-1 Compliance Program
You can enlist Foreside Compliance Services, LLC either to assist your existing CCO on a consulting basis, or to provide a qualified individual to serve in the capacity of CCO for your funds. Our CCOs utilize Foreside's comprehensive compliance work flow system to monitor a fund's Rule 38a-1 Compliance Program.
Developed over an extensive period by our own experienced CCO staff, including seasoned securities lawyers, Foreside's program covers all of the critical fund compliance areas with detailed check-points against the appropriate regulatory references. The program can easily be tailored to a specific fund Board's requirements.
Foreside's program is carefully monitored pursuant to our extensive compliance program matrix, which consists of major compliance review areas with multiple sub-sections (please see example below).
Fund Compliance Review Areas Include:
ADEQUACY AND ACCURACY OF FUND DISCLOSURE
DISCLOSURE OF PORTFOLIO HOLDINGS AND OTHER NON-PUBLIC INFORMATION
GOVERNMENTAL/REGULATORY REPORTS AND FILINGS
FUND GOVERNANCE (BOARD COMPOSITION, BOARD COMMITTEES)
BUSINESS CONTINUITY
CODES OF ETHICS AND INSIDER TRADING POLICIES
TRADING PRACTICES
PROXY VOTING
FEES AND EXPENSES
INVESTMENT POLICIES AND RESTRICTIONS
PORTFOLIO MANAGEMENT PROCESS
HANDLING OF FUND ORDERS
SHAREHOLDER COMPLAINTS/SHAREHOLDER PRIVACY
BROKER-DEALER SUPERVISOR PROCEDURES FOR FUND SALES
FUND ACCOUNTING PROCEDURES/FINANCIAL CONTROLS
CUSTODY OF FUND PORTFOLIO SECURITIES
RECORDS RETENTION/DESTRUCTION
INSURANCE COVERAGE
For further information please contact:
DAVID WHITAKER
Chief Operating Officer, Foreside Financial Group, LLC
News
Sep 30 2009
Foreside is pleased to announce Susan Mosher has joined Foreside as President of Foreside Alternative Investment Services ("FAIS"). more
Sep 25 2009
Foreside is pleased to expand its current relationship with Turner Investment Partners. more
Sep 21 2009
Foreside is pleased to expand its current relationship with Bridgeway Capital Management, Inc. more
Sep 15 2009
Foreside welcomes Ardmore Investment Partners LLC as a new client to our firm. more
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