
We often conduct reviews of our investment management clients' practices and procedures under the Investment Company Act, the Investment Advisers Act and otherwise. These voluntary reviews are tailored to the specific needs and requirements of each client. Our compliance work also takes the form of due diligence reviews of money managers that are candidates for acquisition. In these reviews, we examine areas such as portfolio management, trading, marketing, record-keeping, ethical wall compliance and personal trading.
We have served as independent consultants to clients in conducting reviews of their current practices and procedures under various aspects of the Investment Advisers Act, including reviews mandated by SEC settlements of enforcement actions. In addition to performing compliance reviews, we provide ongoing advice to our investment advisory clients on many regulatory and supervisory issues. As part of this work, we are regularly called upon to answer questions relating to record-keeping, contracts, trade allocations, personal trading and other complex compliance issues.
Similar compliance reviews have been conducted for investment advisory clients on a voluntary basis to help them focus and improve their procedures in the areas of insider trading, personal investments, inter-fund transfer and allocation practices, ethical wall procedures, and books and records requirements under the Investment Company Act and Investment Advisers Act.