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Compliance: An ounce of prevention is worth days of time with the regulators.

With over a billion dollars under management, a Registered Investment Advisor (RIA) and Commodity Pool Operator (CPO) firm was concerned about their compliance requirements. Rule violations during a routine audit by the Securities Exchange Commission (SEC) or the National Futures Association (NFA) would be detrimental to the firm's reputation and an embarrassment to the clients who trusted them with managing their money.

To combat any potential compliance issues or rule violations, this firm hired a consulting firm that specializes in performing mock audits for RIAs and subscribed to CCS Financial Services' Constellation Compliance System™ to monitor and implement procedures for remaining in compliance with NFA Rules and Commodity Futures Trading Commission (CFTC) Regulations.

As part of the CCS Constellation Compliance System™, the required procedure manuals were reviewed and updated to meet the ever changing NFA Rules and CFTC Regulations. Procedures were then analyzed to determine if they were actually being followed by firm personnel. During an annual field review (a mock NFA regulatory audit) all Rule and Regulatory violations were examined, and solutions were presented to abolish all problems.

After completion of the CCS Constellation Compliance System™, the NFA happened to schedule an audit of the firm. NFA auditors planned to be in the firm's office for a week, but, in fact, it turned out to be only one day. The brevity of this audit was due in large part to the preparation and organization that was in place. The registration files, compliance procedures, and accounting records were in compliance and organized in a manner in which the NFA is accustomed to.

CCS' Constellation Compliance System™ is so successful because it was developed by Richard Yasak, a prior NFA Compliance Auditor and Compliance Officer of a prominent brokerage firm.

Value Added:

  • Your firm does not have to use personnel to read, interpret, and document procedures to stay in compliance with voluminous rules and regulations.
  • You save time and aggravation by decreasing the time the regulators are camped in your office asking you the same questions three different ways.
  • You stay focused on the core of your business because you gain peace of mind that your compliance operation was reviewed by a third party prior to the regulatory audits.
  • The scheduling of your next regulatory audit can be less frequent since this audit was in complete compliance.

This example proved that the value added outweighs the cost of the CCS Constellation Compliance System™.

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Accounting: Streamline your back office – Outsource.

Proctor and Gamble, one of the largest firms in the world, made a corporate policy to outsource billions of dollars worth of back office operations. They wanted to concentrate on their marketing and product lines instead of managing the back office functions, but recognized that both are equally important to the overall business structure and plan.

Whether you are a multi-billion dollar business or just starting out from an extra bedroom in your home, accounting for your business and clients is crucial. Being able to streamline your back office needs saves you time, money, and allows you to focus on the area of your expertise.

An investment advisor was referred to CCS Financial Services to help develop a more efficient back office operation. He managed a handful of accounts and had fifty or so client accounts ready to allocate money. The challenge of his operation was that every new client was to be charged a different management and incentive fee. Some would not be charged a fee until a high-water mark was achieved and others were charged a flat rate. To complicate matters, the investment advisor offered different trading programs and clients were able to switch investments between programs.

If there were three trading programs and fifty clients, there could have been 150 accounts to keep track of (manage, allocate trades, reconcile, etc.). Running this type of back office might have required a small army of staff, but CCS developed a Fund structure that had multiple classes as well as individual fee structures. The structure allowed clients to move their investment from one class (trading program) to another once a month with virtually no additional back office support.

By outsourcing their accounting functions to CCS, state-of-the-art accounting programs were utilized to generate all accounting reports and client account statements. Instead of a large personnel investment, the firm only needs one part-time staff liaison with CCS.

Value Added:

  • Less back office staff to manage.
  • Timely reporting using state-of-the-art computer programs with PDF file transfer.
  • A part-time back office function for the firm.
  • Less payroll expense.
  • In most cases, the Fund pays for this accounting function.


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Registration: Can be either months of resubmissions or just a walk in the park

Getting registered can be compared to a walk in the park or a trip to the dentist for a root canal. We have heard stories of how fingerprint cards, checks in the wrong boxes on forms, and incomplete data can delay registration for months.

A recent example is someone who wanted to become registered as a Commodity Trading Advisor (CTA) and after months was still in the process.

The prospective CTA then hired CCS to expedite the process. CCS needed only an hour of his time before completing all of the necessary resubmissions. The firm was up and running in a few weeks instead of a few months.

As stated by the newly registered CTA, without CCS' help, he still would have been waiting.

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