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  • OUTSOURCING UPHELD: Recent ruling supports use of outsourced CCO read more >>
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New! In your corner

Brief case histories that illustrate the many ways CCS expertise works to solve problems for our clients..
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Compliance Outsourcing Recognized in Form ADV

11 June 2015

In a recent amendment to the SEC’s Form ADV and the Investment Advisers Act, financial advisers are now required to...
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Todd Cipperman

quoted in Wall Street Journal

The Morning Risk Report: Ruling Helps Firms Make Case for Outsourced CCOs
Read Here

Todd Cipperman

quoted in Wall Street Journal

Read the Article

Featured Blog Articles

Private Equity Firm Will Pay $28 Million to Settle Expense Allocation Charges


“A large private equity firm agreed to pay over $28 Million in disgorgement, penalties and interest for failing to allocate broken deal expenses to co-investing funds created for...”

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SEC Won’t Allow Access Persons to Exclude All Third-Party Investment Accounts from Code of Ethics Reporting


“The staff of the SEC’s Division of Investment Management has warned that delegating investment discretion over a personal account does not by itself exempt the account from...”

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Auditor Failed to Complete Custody Review Engagement


“The SEC fined and barred an audit firm and its principal for failing to complete...”

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How Good Is Your Compliance Program?

Will it withstand SEC scrutiny during a regulatory exam? Do you assess your regulatory risk the same way that the SEC does? Should you be worried?

Worst-case scenario: You’ve done something so egregious that the SEC lawyers refer the case to Enforcement, which could lead to public censure, fines, expensive undertakings, and industry bans.

Least-bad scenario: A problem shows up on a deficiency letter that a potential client will see.

In between: You and your firm become entangled in an ongoing regulatory dialog with the SEC that costs time and money. And, once the SEC determines that you or your firm is a compliance risk, you will likely see the examiners on an annual (if not continuing) basis.

Turn to CCS

With the increasing complexity and visibility of regulatory oversight, investment organizations are choosing to utilize independent partners to develop and execute compliance programs.

Cipperman Compliance Services (CCS) provides compliance services to registered funds and money managers. CCS creates compliance solutions that work for dynamic firms by leveraging the experience of a multi-disciplinary team of lawyers, compliance and operations professionals, and applying a management-focused approach to client services.

CCS takes full accountability for implementing its advice and solutions, which include serving as a firm’s chief compliance officer, creating customized compliance programs, conducting compliance reviews, and responding to regulatory inquiries.

Compliance Rules

Let's walk through the new SEC regulations.