Who do we work for? Our client list is custom-tailored to the broad range of expertise we offer. Institutional money managers and large sell-side firms seek us out for our specialized offerings not found elsewhere. Clients include middle- and large-market SEC advisers, private fund advisers including hedge fund, private equity and fund of fund advisers (FOFs), insurance company affiliates, managers of managers and large indie firms with numerous branch offices.
Here are just a few examples of how FrontLine Compliance has supported its clients over the
years and the outstanding results FrontLine Compliance has achieved.
Forensic Testing Program – A Client’s Commentary
A FrontLine Compliance client had this to say about our value-add Forensic Testing Program:
“The forensic testing program is a crucial resource; it can be a real challenge for a CCO to know what constitutes good testing and even, in some cases, how to do it. Being able to rely on real experts in the field gives me a lot of confidence in facing an exam as well as in the strength of our program and conducting our annual review; it also allows much more thorough testing and documentation than I would have been able to complete with the time and resources I have available. And I learn from our results! FrontLine offers guidance on areas where my knowledge is weaker and sometimes has, through feedback, updated me both on what the SEC seeks and on market and industry practice. So, FrontLine offers both knowledge and solutions!”
– General Counsel and CCO, Hedge Fund Client
Regulatory Response Services
Several of our long-term clients underwent routine regulatory examinations from 2020-2022. The pandemic did not keep the regulators from conducting examinations. These were both SEC and NFA exams. Most of the clients are regular participants in our Quarterly Forensic Testing Program which made for a very smooth exam process with minimal deficiencies and no material findings.
Once again, our clients sailed through their exams guided by the regulatory experience of our Founder alongside our seasoned experts. FrontLine Compliance has an unmatched historical track record of client regulatory exams demonstrating compliance successes. Since our founding in 2006, no client we’ve created and supported an ongoing testing program for has ever had a material finding from a SEC, NFA or FINRA regulatory exam.
Annual Compliance Reviews
FrontLine Compliance assists the majority of its clients with their Annual Compliance Review. Our proven system of thorough testing combined with a comprehensive and cohesive written report has been stress tested by regulators many times over the years. Our clients have received positive comments back from regulators each time.
Case Study: A large indie firm client was to have its Annual Compliance Review conducted by its Internal Audit Department, but found out just two weeks before the report was due that the Internal Audit team could not complete the task due to scheduling issues. FrontLine was hired to pick up the slack and complete the review, including all testing, in less than two weeks. Even with the short time allotted, FrontLine consultants performed an on-site GAP analysis, conducted the forensic testing, and created a comprehensive written report for the Board of Directors. All on time and under budget!
SEC Exam Prep
FrontLine Compliance helps firms of various sizes face their SEC exams. We work with our clients to ensure that all documents produced are accurate, responsive, and contain no “red flags.” Our mock exam and mock interviews successfully prep firms. In one case, the SEC visit lasted less than three days and resulted in no findings whatsoever. Just as we planned!
A large dual registrant hired FrontLine Compliance to bridge the strategic gap between its business line managers and its compliance department. The business side had important goals to expand third-party relationships, launch new products and acquire additional firms. But compliance wasn’t on board because of unanswered questions. With the two sides bogged down, they called us to help them navigate through the impasse. Working closely with both sides, we ironed out differences to bring them together in a way that made each side comfortable in moving forward with a unified plan.
Education and Training
Although it is technically not required under any specific SEC regulation, during an SEC exam, examiners ask for copies of all training materials provided to employees. The SEC expects firms to train employees on compliance requirements as part of Rule 206(4)-7 or Rule 38a-1 compliance. There is a specific training requirement for NFA registered firms.
All clients of FrontLine Compliance are encouraged to participate in our Annual Compliance Training Programs. Our method of conducting the compliance training ensures that the firm will meet and exceed SEC and/or NFA’s expectations by focusing on employee requirements, ethics, and supervision of employees.