CCS has become the leading provider of CCO services of four primary factors: our 15+ years of performance, our holistic service model, our client engagement, and our industry leadership.
No compliance services firm has provided CCO services longer or to more clients. We helped pioneer the CCO outsourcing model since our founding over 15 years ago.
We take on the role of Chief Compliance Officer because we believe in accountability. Our people have to answer directly to the SEC, thereby creating alignment with our clients. This responsibility ensures that we engage proactively to implement a compliance program rather than await instructions.
We measure our success by our regulatory outcomes. We stand confidently behind our record representing our clients during hundreds of SEC exams during the last 16 years. Clients have told us that they appreciated that we managed their exams, minimized deficiencies, and rapidly responded to SEC comments.
We also measure success by the success of our clients when questioned by their institutional clients. When compliance becomes a positive rather than a negative during the due diligence process, our clients get closer to landing large mandates.
The success of our CCO offering can be seen in the growth of our clients. Our client base has increased steadily every year since 2004. We now serve as CCO for more registered investment advisers than any other compliance firm. More investment firms than every are embracing the CCO outsourcing model and turning to CCS as a tried and trusted provider. Our current clients serve as our greatest source of new business and as terrific references. Rarely, if ever, do we lose a client to a competitor.
CCS leads the industry with its multi-faceted, ongoing client engagement process.
CCS staffs every client relationship with a team of at least two professionals. We utilize a highly customized and interactive service model designed to become integrated with internal operations. Every client team is led by a senior compliance professional with 15+ years of industry experience. In addition, the team includes a program manager with 5+ years’ experience.
The service team follows a comprehensive engagement and communications schedule. CCS commits to no less than 6 on-site visits per year to conduct a range of scheduled activities including testing, reporting, information exchange, and training. We also schedule weekly compliance calls to discuss new business initiatives, employee changes, Code of Ethics reporting, testing, annual reviews, and the progress of service initiatives. Our relationship begins with an intensive onboarding process where the service team and the onboarding team come on-site to take over the compliance work.
We are accessible by phone and email on a 24/7/365 basis. We commit to responding to every request within 120 minutes and provide an answer within 24 hours. Our marketing review team commits to turning around every piece of marketing with required disclosures within 24 hours (or more quickly if an emergency). If, for some reason, your primary point of contact does not respond within acceptable time periods, you will have the cell phone number of each member of the team to ensure “up-the-ladder” service accountability.
All Client Engagement activities are managed and supervised by the firm’s Director of Client Engagement, one of the firm’s senior leaders.
Our program is designed to include all services expected of a world class compliance function. We charge a fixed monthly fee to ensure budget predictability. We license a third party system (BasisCode) at no additional cost to our clients to manage the Code of Ethics personal trade reporting requirements. We have also partnered with a third party IT firm (Align) to provide cybersecurity assessments at no additional cost. We have also licensed a file-sharing application (Box) to provide access to all compliance documents at any time. We want our clients to use us as they would use an in-house compliance function: available, dedicated, transparent.
Nobody writes, comments, speaks or discusses more about investment management compliance issues than Todd Cipperman and Cipperman Compliance Services. Todd has written a daily compliance blog since 2008. The blog, which is distributed to over 7000 people per day, is recognized as a leading source of compliance information. The blog led to the 2018 publication of Todd’s book: The Compliance Advantage: 10 Must-Know Trends to Protect Your Investment Firm. Todd is also frequently quoted in the national press and appears regularly on business news shows.
Our thought leadership also extends to the regulators. We have met with OCIE staff about our activities and solicit input from examiners whenever possible. We also engage with FINRA and fund boards. We see these conversations as opportunities to make our program better and stay ahead of regulatory priorities and trends.