The compliance requirements and challenges for registered investment vehicles has grown increasingly complex since the implementation of Rule 38a-1 of the Investment Company Act of 1940 (“1940 Act”).
To ensure that they meet today’s stringent compliance requirements, all registered funds are required to have a Chief Compliance Officer (CCO). Gemini, via our sister firm, Northern Lights Compliance Services, LLC (NLCS), provides an experienced, qualified person to act on an independent basis as your fund’s CCO. In that capacity, your NLCS compliance officer will report directly and only to your fund’s board of directors/trustees. Our staff includes attorneys, former regulators, former CPAs/auditors, former CCOs, and operations professionals who are proficient in fund compliance requirements. This diverse experience enables us to evaluate the steady stream of new regulations from many different perspectives, resulting in practical and cost-effective implementation strategies.
For fund managers who register their funds in a Gemini-sponsored series trust, NLCS will provide the required CCO. Those who operate a standalone fund with Gemini may also utilize NLCS for their fund CCO needs.
We offer comprehensive compliance services for investment companies and compliance consulting and support services to Registered Investment Advisors (RIAs).
Investment Fund Services: Named CCO
Through NLCS, our goal is to help ensure that registered funds meet the SEC’s stringent regulatory compliance requirements. We assist funds in complying with the federal securities laws (defined by Rule 38a- l) and meeting the responsibilities as outlined by Rule 38a-1 under the 1940 Act, as amended. Our broad program is tailored to meet the needs of small- to medium-sized funds that are seeking a cost-effective alternative to hiring a CCO on a full-time basis. We will provide an experienced, qualified, and independent person to act as the fund CCO.
As the fund’s named CCO, we provide the following services:
Registered Investment Advisor (RIA) Services: CCO Support
Through NLCS, we can help RIAs keep pace with the rapidly-changing compliance environment by offering a full complement of compliance services. We collaborate with your firm’s management to identify regulatory challenges and then build and implement customized practical solutions designed to meet your firm’s regulatory responsibilities.
NLCS provides the following additional ad hoc compliance services that you can purchase as the need arises: