Welcome to Adviser Compliance Consulting

Proactive Compliance Solutions For Your Business

Our Services

Welcome to Adviser Compliance Consulting

Proactive Compliance Solutions For Your Business

Our Services
Adviser Compliance Consulting Inc.

About Us

Adviser Compliance Consulting Inc. (ACC) is a compliance consulting firm that provides pro-active compliance solutions to registered investment advisers, hedge funds, private funds, investment companies, private equity and financial professionals, including outsource CCO service. ACC has extensive experience in the global asset management industry, which includes over twenty years in the Investment Company/Investment Adviser and international compliance area.

Specialties Include:

  • Investment Adviser (Rule 206(4)-7), Investment Company (Rule 38a-1) and Private Fund Compliance Programs and Outsource CCO
  • Investment Company Act of 1940 Requirements
  • Anti-Money Laundering Programs for Investment Company, Investment Adviser and International Funds
  • Policies and Procedures, Annual Reviews, Mock SEC Examinations, Risk Assessments and Compliance Training
  • NFA registration of Commodity Pool Operator (CPO) and Commodity Trading Advisors (CTAs), NFA/CFTC compliance program development (including all required Written Supervisory Procedures/Compliance Manuals), compliance program maintenance, regulatory filings, annual reviews (completion of self- examination questionnaires), training of internal personnel regarding compliance requirements of CPOs/CTAs, Ethics Training required of Associated Persons of CPOs/CTAs, NFA audit preparation (mock audits) and audit assistance to CPOs and CTAs
  • International Compliance Program and UCIT regulatory requirements – (UK, Luxembourg, Ireland and Hong Kong)

Services

Assist with developing critical compliance documents and updating and/or submitting required securities and advisory representative filings:

  • Developing Forms ADV Parts 2A and 2B
  • Filing Form ADV Parts 1 & 2A
  • Developing a Privacy Notice
  • Updating and Filing Form U4
  • Developing the code of ethics in accordance with Rule 204A-1 of the Investment Advisers Act
  • Developing written policies and procedures in compliance with Rule 206(4)-7, other current regulatory requirements, as well as industry best practice
  • Review of Critical Compliance Documents
  • Annual Review Planning, Management & Oversight
    • An Annual Review Organizer, including a Risk Assessment & Monitoring Schedule
    • Independent Forensic Testing and Reviews, as agreed upon
    • Quarterly Sync Up
    • Summary Report
  • Regulatory Filings
    • Annual ADV Amendment and any interim updates, if necessary
    • Section 13
  • Unlimited Remote Consulting
  • On-Site Visits
  • Compliance News, Updates & Alerts
  • SEC Exam Support
  • Regulatory filings and Updates
    • ADV
    • Form 13f/H
    • Form PF
  • Annual Risk Assessment
  • Update and Customize Policies and Procedures Manual
  • Rule 206(4)-7 Annual Compliance Program Review and Report
  • Compliance Program Calendar
  • Cybersecurity Compliance Analysis
  • Advertising Reviews
  • Quarterly personal trading, email and social media review
  • Regulatory exam oversight and support
  • Weekly or Monthly onsite Visits
  • Unlimited Remote Consulting
  • Compliance Training and Mentoring
  • All the offerings in deputy CCO package
  • Compliance with all requirements of the Rules 206(4)-7 or 38a-1
  • CCO designation

*Requires CCO Liability Insurance 

Prepare for a SEC examination by simulating the experience through a Mock SEC Examination, which will include:

  • Document Request list
  • Offsite reviews
  • Onsite visit that consist:
    • Interviewing key personnel
    • Review books and records
    • Training
  • Mock report of the findings
  • Consulting on implementation of recommendations
  • Post exam assistance
  • AML/KYC Reviews
  • Regulatory Filings
  • Implementing compliance technology
  • Advertising and social media reviews
  • Email reviews
  • Personal and Portfolio trading reviews
  • International compliance
  • Focused performance review
  • Cybersecurity focused review
  • Due diligence
  • Pay-to-Play reviews
  • Insider trading reviews
  • Training and mentoring
  • C- Level advice on Compliance
  • NFA/CFTC
  • Draft CPO compliance policies / written supervisory procedures
  • Lead registration process including NFA membership, CPO firm registration, Swap Firm registration, as necessary, registration of Principals of CPO, registration of Associated Persons of CPO, registration of Swap Associated Persons of CPO, as necessary, registration of executive officers of CPO (Chief Compliance Officer, etc.)
  • Conduct remote training with respect to compliance obligations of Associated Persons, Principals and NFA-registered executive officers
  • Serve as NFA Security Manager;
  • Conduct Instructor-Led NFA-Required Ethics Training for Associated Persons, upon request;
  • Provide NFA Recordkeeping Tutorial upon request;
  • Provide NFA Promotional Materials Tutorial upon request;
  • Complete Annual NFA Registration Update;
  • Complete Annual Firm and Disaster Recovery Electronic Questionnaire filings;
  • Complete Annual Self-Examination Questionnaires;
  • Review, update and revise Written Supervisory Procedures as necessary to reflect current business practices and emerging regulatory requirements (including annual review of Privacy Policy);
  • Maintain Compliance Calendar;
  • Review and confirm registration information within NFA’s automated system of each of the CPO’s Principals, Associated Persons, Swap Associated Persons (as relevant) and Executive Officers on an annual basis;
  • File Form 8-T to de-register Associated Persons/Swap Associated Persons, as necessary; and
  • Conduct Disclosure Document filing, as necessary
  • Cybersecurity Services
  • IT Services
  • Data Protection
  • CCPA
  • GDPR
  • BCP
  • GIPs
  • Legal
Unlimited Consulting

We promote open and consistent communication throughout the entire engagement by offering unlimited consulting. Consulting via phone calls, emails, and web conferencing is included in the fee for the duration of the engagement.  We do not charge by the hour so that you will feel at ease to contact us at any time with any question that pertains to the scope of the engagement.

Founder

Tito Pombra, President and Founder

Education

B.A., Accounting and Economics, Queens College, NY

PROFESSIONAL AFFILIATIONS

Co-Chair of the San Francisco Bay Area CCO Committee

Former Board of Director, National Society of Compliance Professionals (NSCP)  and current member of NSCP

Former member, Investment Company Institute’s (ICI) CCO Committee

Former CCO of large investment adviser and mutual fund

Tito Pombra is the Founder and President of Adviser Compliance Consulting Inc. (ACC) a compliance consultation firm which services, registered investment advisers, hedge funds, private funds, investment companies, financial professionals, global managers and CPOs.  Over the years, Mr. Pombra has garnered extensive experience in the global asset management industry, which includes twenty-three years in the investment Company/investment adviser and international compliance areas.  His practice is focused on the areas of regulatory exams, acting as outsource CCO, annual reviews, mock SEC exams, creating a strong culture of compliance, policies and procedures development, advertising and marketing reviews, NFA/CFTC compliance and mentoring and training compliance professionals.  

Before founding ACC, Mr. Pombra was President of Core Compliance and Legal Services, where he led the compliance consulting practice to identify and execute new business strategies that resulted in significant new client’s acquisition and growth. In addition, he provided proactive compliance advice to clients on Investment Adviser (Rule 206(4)-7), Investment Company (Rule 38a-1) and Private Fund Compliance Programs. Established policies and procedures, completed annual reviews, mock SEC exams, risk assessments and compliance training for variety of investment advisers.

From 2005 thru 2018, Mr. Pombra was Chief Compliance Officer of Matthews International Capital Management, LLC (“Matthews Asia”) and Matthews International Funds (d/b/a Matthews Asia Funds). As CCO for Matthews Asia and Matthews Funds, he was responsible for creating and managing the compliance and anti-money laundering programs of the Investment Company, Investment Adviser and offshore funds, and assisted with the compliance programs of Matthews Global Investors, Hong Kong and UK, registered broker dealers.  In addition, he oversaw the Matthews Asia Funds service provider’s compliance program under Rule 38a-1.  During his tenure, Mr. Pombra was also the AML Officer for the Matthews Asia Funds and MLRO for the Matthews Asia Funds (Luxembourg). 

Mr. Pombra also held various senior compliance and accounting positions at Franklin Templeton Investments and Dreyfus Funds. He graduated from Queens College, NY (1987) with bachelor’s in accounting and economics.

Over the past 23 years, Mr. Pombra has established an influence in the industry as a thought leader on best compliance practices. He is Co-Chair of the San Francisco Bay Area CCO Committee and a former member of the Board of Directors of the National Society of Compliance Professionals (NSCP) and the Investment Company Institute’s (ICI) CCO committee.

In 2008, Mr. Pombra was named as a Top 20 Rising Star for “Who’s Who” in Upcoming Compliance Professionals by Compliance Reporter magazine. He frequently speaks at industry conferences such as NSCP, Investment Company Institute, Investment Adviser Association, IA Watch, Private Equity Institute, and many others on a wide variety of compliance related subjects.

Contact Us

Call Us

(650) 703-2159