To buy, or not to buy: When it makes sense to Utilize the fund administrator as CCO

Compliance with SEC Rule 38a‐1 and the requirement for a fund to have a chief compliance officer (CCO) requires fund companies to take an in‐depth look at how their organizations deal with compliance as a whole and how their service providers fit into the compliance equation. A fundamental consideration is cost, and the CCO role can carry a significant price tag. Experience counts too. Even though the functions of this role are spelled out, the role is yet untested in the industry. Hiring an outside CCO and outsourcing compliance services offer several benefits to a fund including economies of scale, consistency, the outsourcing provider’s breadth of experience and expertise, and elimination of conflicts of interest within the investment advisor organization when separate resources/staff conduct compliance activities.