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Silver makes a culture of compliance realistic

Today, investment firm compliance best practices call for ample resources and independent input. Both regulators and investors expect continual dedication of resources to compliance and third-party testing.

Silver clients are private equity, venture capital, hedge fund and crypto/digital asset firms contemplating SEC investment adviser registration and registrants outsourcing ongoing compliance functions. Our early entry into the crypto space positioned Silver at the forefront of creating the industry’s compliance best practices for firms fully dedicated to investing in digital assets and those incorporating digital assets into a broader investment mandate.

Silver also advises investment firms in need of SEC exam support or looking for a fresh set of eyes to test their compliance programs.

Registration and Foundation

Well position firms to cross registration milestones

Ongoing Maintenance 

Keep compliance programs effective and above scrutiny

Compliance Assessment 

Equip registered firms for regulatory exams

Exam Support

Guide firms through regulatory exams

Registration and Foundation

Well position firms to cross registration milestones

  • Regulatory risk review
  • Draft and file Form ADV
  • Customized, relevant Compliance Manual, Code of Ethics and related policies and procedures
  • A compliance calendar tailored to the firm’s compliance program and business practices
  • Marketing material, website and social media review
  • Initial staff training session

Ongoing Maintenance

Keep compliance programs effective and above scrutiny

  • Continuous regulatory risk and compliance program review
  • Management of a compliance calendar tailored to the firm’s compliance program, business practices, testing plans and exam history
  • Updates to Form ADV, Form CRS, Form PF and other regulatory filings
  • Updates to Compliance Manual, Code of Ethics and related policies and procedures
  • Employee Code of Ethics disclosure review
  • Marketing material, investor communication, website and social media review
  • Annual Review, including testing, a findings report and recommendation implementation
  • Annual, new employee and thematic trainings
  • Regular deadline reminders and updates on new industry and regulatory developments

Compliance Assessment

Equip registered firms for regulatory exams

  • SEC Preparedness Reviews test document production and prepare firms for regulator interview
  • Mock SEC Exams probe, like regulators, for compliance and operational weaknesses
  • Forensic Testing analyzes specific firm practices such as expense or investment allocation, marketing, best execution and inside information practices
  • Findings Implementation effects recommendations made by Silver or another company

Exam Support

Guide firms through regulatory exams

  • Prepare firms for the regulator exam process and interviews
  • Lead initial document and follow-on request production
  • Develop deficiency letter responses and any resulting disclosures, policies or procedures

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June 21, 2024

Enforcement in Digital Asset Space Hits All-Time High – Is Your Firm Prepared for an Examination?

Preparing for a possible SEC exam revolving around digital assets requires meticulous attention to a variety of critical areas that Silver's Compliance Team covers in this article to help prepare private fund managers and investment firms for success under regulatory examination and investor due diligence.
  • Nicholas Nunez
    Nicholas Nunez
    Managing Director, Chief Administrative Officer & Head of Regulatory Compliance
Contact us to learn more about Silver and our Regulatory Compliance Services

646-838-1687
[email protected]

Nicholas Nunez
Managing Director, Chief Administrative Officer & Head of Regulatory Compliance

646-838-1687
[email protected]
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With over a decade of regulatory compliance experience, Nicholas Nunez works with investment advisers and broker dealers to register with regulatory authorities, develop and maintain their compliance programs and withstand scrutiny under both regulator examination and investor due diligence. In addition, Nicholas works with the CEO to manage the operations of Silver.

Prior to joining Silver, Nicholas served as the Deputy Director of Compliance at Commonwealth Opportunity Capital (CWOC), an SEC and CFTC-registered adviser that employed global macro strategies. At CWOC, he ensured implementation of numerous aspects of the compliance program, including development and execution of policies and procedures, administration of forensic testing and management of compliance trainings and also served as the firm’s cybersecurity responsible officer. Prior to CWOC, Nicholas was an Associate Director at CounselWorks LLC, a regulatory and business strategy consulting firm to investment advisers and broker dealers.

Nicholas holds a Bachelor of Science in Business Administration from Saint Joseph’s University and is proficient in Italian.