Limiting fixed expenses without sacrificing quality
A start-up ETF sponsor needed assistance with establishing a compliance program ahead of their organizational board meeting. The firm had an excellent compliance culture, but wished to limit their fixed expenses and was committed to an outsourced model for many of the services their ETFs would require.
Foreside proposed an experienced Fund Chief Compliance Officer candidate to the sponsor. Working closely with the adviser chief compliance officer and fund counsel, Foreside drafted a tailored compliance program for the proposed ETFs. Foreside also reached out to each of the proposed service providers requiring review under Rule 38a-1, obtaining and reviewing their compliance programs.
At the organizational board meeting, Foreside was able to represent to the board that the ETFs’ compliance program and that of each service provider, was reasonably designed in order to prevent violation of securities laws. Foreside was appointed as Chief Compliance Officer during the organizational board meeting and continues to serve in that capacity, as well as Anti-Money Laundering Compliance Officer for the ETFs.
All situations are evaluated, and results may be different depending on the situation. It is important to note these case studies are not testimonials but examples of strategies that have been deployed to assist our clients. These examples may not be representative of your experience with Foreside and do not guarantee that you will experience the same or similar results.
Foreside and its affiliates do not provide tax, legal, or accounting advice. The case studies are provided for informational use only and should not be relied on for tax, legal, or accounting advice.