Steelbridge Compliance Brochure

Compliance delivered with Perspective, Purpose & Practicality.STEELBRIDGE COMPLIANCE LLC2626 COLE AVENUE. SUITE 400

DALLAS. TEXAS 75204

(214) 960.4810

[email protected]

WWW.STEELBRIDGECOMPLIANCE.COM


DALLAS. TEXAS 75204

(214) 960.4810

[email protected]



DALLAS. TEXAS 75204

(214) 960.4810

[email protected]



DALLAS. TEXAS 75204

(214) 960.4810

[email protected]


Perspective. Purpose. Practicality.

The Steelbridge Di�erenceSteelbridge Compliance is di�erent from other compliance service providers.

We are attorneys and CPAs with decades of combined operational experience

at leading fund organizations - not just outside service providers or former

public sector personnel.

Steelbridge Compliance is focused on "real world" solutions tailored to your

specific business and needs - not one-size-fits-all best practices, and no

excessive and irrelevant inquiries.

Steelbridge Compliance is sensitive to minimizing disruption and expense,

while adding value and e�ciency to your business. That is why services are

strictly flat-fee.

Steelbridge Compliance maintains strong relationships with regulators,

investment advisors, investors, industry trade groups and other industry

service providers, and has a deep understanding of the compliance

requirements required by each constituent group.

2 . 8 WWW.STEEBRIDGECOMPLIANCE.COM


Product and Services O�erings

The SEC requires it. Investors want it.

• Compliance Program Review. (Annual or Quarterly)

• Tier 1: High level risk based assessment in light of requirements.

• Tier 2: Assessment based on current policies and procedures and gap analysis.

• Tier 3: Procedure creation and modification based on gaps.

• Mock Audits and Exams.

• Specialized Reviews. (Code of Ethics, Privacy, AML, other program components)

• Specialized Testing of Processes and Internal Controls.

The exemptions are now very narrow, and registration is likely required.

• Registration, SEC and states.

• ADV Part I & Part II.

• Filing Support, Federal and state.

Do not let projects linger. Outsource them.

• Business Continuity and Disaster Recovery Planning/Testing.

• SEC/state Exam Support.

• Restricted Securities Reviews and Legend Updating.

• Book and Record Compilation and Organization.

• Onsite and Offsite Compliance Training.

Product and Services O�erings

The SEC requires it. Investors want it.

• Compliance Program Review. (Annual or Quarterly)

• Tier 1: High level risk based assessment in light of requirements.

• Tier 2: Assessment based on current policies and procedures and gap analysis.

• Tier 3: Procedure creation and modification based on gaps.

• Mock Audits and Exams.

• Specialized Reviews. (Code of Ethics, Privacy, AML, other program components)

• Specialized Testing of Processes and Internal Controls.

The exemptions are now very narrow, and registration is likely required.

• Registration, SEC and states.

• ADV Part I & Part II.

• Filing Support, Federal and state.

Do not let projects linger. Outsource them.

• Business Continuity and Disaster Recovery Planning/Testing.

• SEC/state Exam Support.

• Restricted Securities Reviews and Legend Updating.

• Book and Record Compilation and Organization.

• Onsite and Offsite Compliance Training.

Assessments & Reviews

Advisor Registration &

Filings

Focused Services & Reviews


The Dodd-Frank Act of 2010 may be the most sweeping financial regulatory reform since the Great Depression.

Most advisors have been relying on the fifteen or fewer client exemption to registration.

It is gone.

Registered advisors must have annual written compliance reviews.

The SEC now wants to see fund trading positions, side letters, and all uses of leverage.

Business Continuity — what happens if the largest investor leaves?


Dear Advisor:

The Dodd-Frank Act requires most advisors of private equity and hedge funds to

register with the SEC or the states, and sets a deadline of one year from its enactment

on July 21, 2010 to do so. Advisors should be wary of that deadline though.

Currently, it can take upwards of two months for the SEC to approve an advisor's

registration. Next year, an expected flood of new registrations is likely to create a

backlog that could extend this timeline. The situation could be even worse for

advisors registering with the states, whose regulatory agencies are generally more

lightly sta�ed and funded.

An advisor that is not appropriately registered with the SEC or states by the

deadline, even during the pendency of its application, cannot charge fees.

Advisors should, therefore, begin the process as soon as possible, including by

establishing and improving their compliance programs. Please let me know if

Steelbridge Compliance can be of help. I also invite you to subscribe to our news

feed for information on new rulemaking and upcoming events at:

www.steelbridgecompliance.com/blog

Best regards,

D. Niknejad

Managing Director

Steelbridge Compliance LLC

(214) 960.4811

[email protected]


“An integrated Compliance Program is robust. It augments your business, while reducing risks and enhancing your firm’s reputation.”

Attract More Investor MoneyThe Dodd-Frank Act is expected to raise the

investor qualification thresholds, limiting

pools to high net worth investors and

institutional investors.

Large and institutional investors demand

strong compliance procedures and back

testing, regardless of the SEC or states.

ROBUST COMPLIANCE PROGRAM

ENHANCE YOUR REPUTATION IN THE MARKETPLACE

Keep the Money You EarnAvoid State and SEC interference and fines.

Shorten SEC inspections and reduce

business distraction.

Low cost, outsourced compliance functions

require fewer internal hires.


Case Studies.

Establishing Your Business & Brand.

New or newly registered investment advisor.

Ensure meeting basic compliance requirements.

• $30m AUM, traditional long-short equity pooled vehicle with some minor separate accounts.• Lightly staffed, without resources to dedicate to compliance issues.

Provision of tailored compliance manual. A low-cost, high level ‘Tier 1’ assessment of current policies, and recommendations for improvement. Registration with state.

Building Your Business & Brand.

Established, SEC registered investment advisor.

Determine if compliance program is robust enough for firm’s growth andnew strategies.

• $100m AUM, two or more pooled vehicles with sizable separate accounts. Multiple asset classes. Initiatives to attract ERISA money and establish an offshore vehicle. • Some compliance staff, but generally dedicated to day-to-day transactional issues.

A detailed ‘Tier 2’ assessment of compliance policies and procedures. Update compliance manual for new initiatives, and review agreements for authority in light of possible “strategy drift”. Gap analysis related to ERISA issues and offshore investors. Determine whether rule changes require re-registration with state. Address legends on restricted securities now eligible for unrestricted trading.

Protecting Your Business & Brand.

Large, sophisticated SEC registered investment advisor.

Ensure meeting compliance requirements of a complex advisor, and that programs and procedures optimize profitability. Clear lingering compliance initiatives o� of plate.

• $2B AUM, multiple on-shore and offshore pooled investment vehicles, including principal accounts. Numerous asset classes and investor types, including institutional investors. Frequent trading in public companies, and several employee directorships. • Significant but stretched compliance staff. Multiple third-party service providers performing many functions touching compliance.

Focused ‘Tier 3’ review of compliance policies and procedures. Gap analysis, assessment, findings and a road map for implementation of program to address UBTI/ECI tax issues, principal trading and trade related filings, and conflicts issues. Coordination with third party service providers to organize books and records in anticipation of SEC exam.

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2626 COLE AVENUE, SUITE 400DALLAS, TEXAS 75204

(214) 960.4810 [email protected]

WWW.STEEBRIDGECOMPLIANCE.COM

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