Educating a Newly-Registered US Investment Adviser
A privately-held, $40B asset manager had expanded its UK-based operations to the US, necessitating its registration with the SEC and adherence to US federal guidelines.
The UK-based compliance team, lacked experience with SEC regulatory requirements and expectations, wished to supplement and expedite internal education efforts with additional training for affected staff, thereby increasing depth of understanding and informing decision-making.
ReGroup collaborated with the firm’s compliance team to develop and implement appropriate training on essential SEC expectations such as the basic requirements of the Investment Advisers Act of 1940, and related interpretations. The comprehensive and customized education included compliance fundamentals, such as conducting annual review testing, as well as industry trends and how to manager regulatory change.
In addition, the client engaged ReGroup to review the firm’s existing written policies and procedures, recommend opportunities to incorporate SEC expectations, and provide a list of proposed policies and procedures that would help establish a FCA-compliant compliance program inclusive of US regulatory terminology and expectations.
The coaching and training of the UK-based staff gave employees the necessary tools to understand and integrate the requirements of the Investment Advisers Act into their existing programs. Both the compliance department and senior management were better able to identify conflicts of interest, and formulate and implement effective compliance strategies. Actionable, risk-based recommendations allowed the compliance team to stage changes to the existing compliance program to help ensure both FCA and SEC expectations were being met efficiently.