GRC Articles

October 11, 2017

Dear Clients and Friends,

It is a common assumption that the EU’s PRIIP Regulation “the PRIIP Regulation” has no relevance to the alternative investment management sector because it applies solely to retail investors. In fact, PRIIP takes a much broader view of who is a retail investor, and is likely to capture employees, as well as friends and family of the investment manager. In this alert, we take a look at the requirements of the PRIIP Regulation and the implications for all managers who take on this new category of investor.


October 6, 2017

The following article was featured in the September 2017 edition of Financier Worldwide. It was written by ACA's Jami Jack and Ken Harman.

It is hardly surprising that European technology investment has grown tremendously over the past few years, given the fresh wave of innovative start-ups coming on the scene each month. As a consequence, Europe is now home to a host of mature yet fast-growing technology businesses, such as Auto1, blablacar, Klarna, iZettle and SumUp. 

September 27, 2017
Protecting Your Business from All Angles —  Preventing a Cyber Incident from the Top-Down and Inside-Out

Cyber incidents can have devastating effects on business of all sizes. A breach or malware attack could cripple business operations, lead to financial losses, expose sensitive data, and cause reputational damage.

September 25, 2017

You may have deliberated, cogitated and digested the impact of MiFID II by now.
You may have considered its implications to the Nth degree, held numerous internal meetings and pushed this new EU directive into every dark corner of your business. Did the summer months feel like one long implementation project, but you now feel you are probably ready or maybe almost-definitely ready? The hard work is done, right? You are ready for ‘M2 date’ in January 2018?

September 12, 2017

Following the SEC’s recent commentary on Initial Coin Offerings, some investment adviser firm employees will now need to report the personal trades they make in certain types of virtual currency tokens.

On July 25, 2017, the SEC issued a series of releases in which the agency articulated, for the first time, its view that virtual currency tokens offered or sold as part of an Initial Coin Offering (“ICO”) may constitute “securities” and that certain types of ICOs are therefore subject to the federal securities laws.

September 6, 2017

Dear Clients and Friends,

The FCA’s most recent consultation paper on the Senior Managers & Certification Regime (“SM&CR”) suggests that fears of an onerous regime are unwarranted. The FCA is proposing to take a flexible and proportionate approach to accommodate the different types of firms in the industry. However, there is still work to be done to become SM&CR compliant.



July 20, 2017

The following article, written by ACA's Danielle Joseph and Anne Wallace, appeared in the Hedge Fund Law Report on July 20, 2017.

May 8, 2017

At the 20th Annual GIPS Standards Conference, back in October 2016, Carl Bacon, chair of the GIPS Executive Committee, and Jonathan Boersma, Executive Director, GIPS, at CFA Institute, provided some insight into the next edition of the GIPS standards, currently being referred to as GIPS 20/20. 

May 8, 2017

The best methodology for calculating and presenting investment performance can be a tricky proposition. The choice will depend on the audience (prospect / current investor) and also what exactly the firm is trying to convey.  In fact, we have seen a slight uptick in interest for showing multiple performance streams. Below, we will explore the two most popular methods for calculating and presenting performance and what they mean for both prospective and current clients.

May 3, 2017

The Guidance Statement on Broadly Distributed Pooled Funds was officially approved on March 13, 2017. The following are highlights of what is included, and what changed from the original drafting.

February 15, 2017

The Global Investment Performance Standards (“GIPS®”) are a set of voluntary, ethical standards developed by CFA Institute in partnership with other organizations worldwide.  The creation of the GIPS standards was spurred by a need for prospective investors to be able to make meaningful comparisons of investment performance across multiple managers, for any given strategy.  As acceptance of the GIPS standards continues to spread globally, adoption remains especially strong in the United States.  Managers that are registered with the U.S.

February 1, 2017

Firms that claim compliance with the GIPS standards are required to notify CFA Institute of their claim of compliance. Each firm must submit the GIPS Compliance Form annually, by June 30th.  Any data included in this form must be as of the prior December 31st.  Firms completing the form currently must include data as of December 31, 2016. Note that the form can be submitted anytime between now and June 30th and is not dependent upon completion of a firm’s 2016 verification.

The 2017 form is now available and includes a few updates.

February 1, 2017

Proposed revisions to the Guidance on the Use of Supplemental Information were released for public comment on December 1, 2016.  The deadline for submitting comments is February 28, 2017.  We discuss key points from this draft Guidance Statement below.

October 17, 2016

The U.S. Securities and Exchange Commission (SEC) last week announced enforcement results for its 2016 fiscal year, which ended September 30, 2016. The results include new single-year records for total cases filed and cases against investment advisers and investment companies. The SEC’s full release is here