After 30 years in the industry, we decided to alter direction.
It is our mission to be the best compliance solutions company for small-and mid-sized asset managers. We have developed the best practices to deliver efficient, customized and responsive compliance services at competitive prices.
Xion Consulting, LLC can help foster a culture of ethics that will increase an understanding of compliance and equip clients with regulatory tools to make sound decisions within the correct legal boundaries.
We will give you peace of mind that your firm is in compliance with up-to-date applicable regulations and industry standards to ensure that your employees are operating in a compliant manner.
Xion Consulting, LLC has developed and implemented compliance programs for registered and unregistered investment advisors, sub-advised funds, hedge funds, private equity funds, broker-dealers and mutual funds. Xion Consulting, LLC ensures that every client receives quality compliance services.
Xion Consulting, LLC is highly skilled in the knowledge of the standards of regulators and the rules that are applicable, as well as, how to develop and implement cost-effective business-oriented solutions.
At Xion Consulting, LLC, our approach is to make firms feel they have a focused, in-house compliance department. We are part of the team and as such, know all the ins and outs of your firm and its specific business needs. We intend to treat your firm as if it were our own and will do everything in our power to protect your firm's reputation amidst ever-changing regulations.
At Xion Consulting, LLC, we are the front-line, we are in the trenches with you side-by-side and you can rely on us every step of the way in maintaining compliance with SEC regulations.
Advertising & Marketing Material Review:
Investment Adviser advertising is regulated under the general anti-fraud provision of the Advisers Act. SEC Advertising Rules prohibit the publication, circulation or distribution of any advertising that is false or misleading. The SEC recognizes that the determination as to whether a given communication is misleading is intrinsically subjective and generally has not provided guidance on this issue. Xion Consulting, LLC's industry experience and knowledge of applicable no-action letters enables us to review advertising material and offer guidance as to whether the material constitutes advertising as defined by the SEC and whether the SEC would likely find it to be misleading.
Codes of Ethics:
The Advisers Act requires investment advisers to adopt a code of ethics that sets forth standards of business conduct and requires compliance with federal securities laws. The code of ethics must address personal trading, conflicts of interest and the safeguarding of material nonpublic information about client transactions. Xion Consulting, LLC can develop a code of ethics that meets the requirements of the Act and is customized to your business model.
Compliance & Ethics Training Development & Delivery:
One of the keys to developing a successful compliance program is to implement a robust compliance training program. An effective on-going training program can help maintain a culture of compliance and provide an opportunity to remind staff of critical areas and educate them about new regulatory requirements and procedures. From new hire compliance training to on-going compliance training for staff, Xion Consulting, LLC can develop and deliver a training program to help your employees meet their compliance responsibilities.
Compliance Policies & Procedures:
The SEC requires firms to document compliance policies and procedures. Documentation of these items help ensure that policies and procedures are being followed consistently within your organization. Xion Consulting, LLC has operations as well as legal and compliance experience that enables us to develop policies that meet regulatory requirements and procedures that are both efficient and effective at controlling and remediating regulatory deficiencies.
Coordination of SEC Inquiries & Exams:
The SEC's Office of Compliance Inspections and Examinations (OCIE) conducts sweeps, regulatory inquiries and exams designed to detect compliance problems and discover weaknesses in firms internal controls that may lead to violations of the federal securities laws. Xion Consulting, LLC keeps abreast of hot areas of review by the OCIE and can assist your firm in gathering and reviewing the requested documents. We will work with your team to prepare appropriate responses to requests for information and we will be your first line of defense with the SEC.
Development of E-mail & Records Retention Policy & Procedures:
Rule 204-2 sets forth the records that investment advisers must maintain, as well as the manner in which such records should be maintained. The Advisers Act, requires that Advisers maintain the originals of all written communications received and copies of all written communications relating to the business of providing investment services, including e-mails, sent to any party, including persons who are not clients of the firm. Xion Consulting, LLC can help you develop and implement a records retention policy that complies with the Advisers Act.
Form ADV Parts I & II:
SEC requires that Form ADV be revised to reflect material changes. Xion Consulting, LLC will review the ADV policy and procedures effective to ensure compliance. Xion Consulting, LLC will check Form ADV disclosures against SEC form requirements to make sure disclosures are up-to-date and accurate and the disclosures in ADV Part I are consistent with those in ADV Part II. We will also check client files to ensure ADV Part II was offered to each client in writing at least annually as required.
International Sales Compliance:
For those firms that engage in solicitation of funds outside the United States, navigating the various international laws is complex and carries significant penalties for violations. Xion Consulting, LLC partners with local counsel to ensure that the laws of each country are clear and up-to-date and that your offering is in full compliance with the laws of the specific country.
Regulatory Crisis Management:
Despite the most effective Compliance Program, a regulatory issue may still arise. How the issue is handled can make all the difference in terms of the impact to a firm's reputation. Xion Consulting, LLC can provide expert guidance as to how best to address the issue and manage communications pertaining to it. From determining whether or not to self-disclose to the SEC to how best to respond to media inquiries and communicating the issue to employees and clients, we will be your trusted partner in navigating your firm's regulatory crisis and guarding its reputation.
Risk Assessments:
The SEC requires that companies perform a periodic risk assessment of their business to identify compliance and operational risks. Our risk assessments are top-tier quality, in terms of identifying and assessing all of the regulatory and operational risks to are present in your business model and recommending and implementing solutions to remediate those risks.
Third-Party Due Diligence:
Investment advisors have a fiduciary obligation to better understand the entities with which it does business. While representations and warranties provided reasonable assurance in the past that service providers' business practices were in compliance with regulatory standards, recent history has highlighted the need for more thorough due diligence. Xion Consulting, LLC has developed a Third Party Due Diligence Process to fully assess the business structure and operations of those entities that seek to do business with your firm.
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