Adviser and CCO


Adviser and CCO

Foreside’s attorneys and compliance analysts understand the regulatory framework under which our clients operate and stay abreast of new regulatory initiatives affecting the industry to ensure your funds remain compliant. We provide quality services in a cost-effective manner, utilizing sophisticated workflow-based tools. Our experienced attorneys work with a diverse client base, serving in the role of fund chief compliance officer (CCO) or as consultant to a fund CCO or investment adviser CCO.

Foreside’s Chief Compliance Officer Services

We provide a qualified professional to serve as the named CCO of your fund on a temporary or permanent basis. Our CCOs will:

  • Conduct periodic reviews of the compliance program to incorporate new or changed regulations or best practice recommendations as appropriate
  • Review the adequacy of the policies and procedures of the fund and its service providers, and the effectiveness of their implementation
  • Design or review risk-based testing methods for the compliance program’s policies and procedures
  • Perform and document testing of certain key control procedures; this process includes collecting and organizing relevant compliance data and reviewing reports, investigating exceptions and making inquiries to fund management and service providers
  • Conduct site visits to advisers and other service providers as necessary
  • Prepare quarterly and annual CCO Reports for the Board and attend meetings quarterly or as requested
  • Meet periodically with fund management
  • Maintain records comprising the fund’s compliance program

Foreside’s Independent CCO Model

We will administer the fund’s Rule 38a-1 compliance program, providing you the peace of mind that Foreside is carefully monitoring and testing the fund’s operations and service providers. Our resources can be particularly helpful for special projects and reviews, especially when you require short-term or periodic help.


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Compliance Consulting Services for a Fund or Adviser CCO

Our experienced attorneys will work with your current CCO to assist with:

  • Compliance program design and implementation, monitoring and testing
  • Risk assessment and gap analysis
  • Best execution/trade management reviews
  • Code of ethics/personal trading review
  • Anti-money laundering review
  • Post trade compliance review
  • Assistance with drafting CCO reports
  • Specialized reviews and compliance assessments
  • Regulator-mandated consulting
  • Regulatory compliance review
  • Service provider compliance program evaluation
  • Mock regulatory exams
  • CCO support services
  • Design and implementation of an operational metrics program
  • Vendor selection


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Terms of Use


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Sonja Formato

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National Account Manager

BA, University of Massachusetts at Amherst; MBA, Boston University

Sonja Formato joined Foreside as a National Accounts Manager in November 2014. Prior to joining Foreside, Sonja worked as a Relationship Manager with Fidelity Investments. While at Fidelity, among other responsibilities, Sonja managed multiple strategic relationships with investment management firms, consulted on product, positioning & marketing strategies to increase distribution and led the build-out of Fidelity’s FundsNetwork Distributor Service Model. Sonja has 20+ years of experience in the financial industry with a passion for assisting clients in navigating the distribution landscape.

Rachel Pham

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National Account Manager

BA, University of South Florida

Rachel Pham joined Foreside as a National Account Manager in October 2014. In this role, Rachel builds strategic partnerships with broker dealers to gain insight onto their platforms, key initiatives and research capabilities. Prior to joining Foreside, Rachel worked as a Relationship Manger with Raymond James Financial. While at Raymond James among other responsibilities, Rachel managed relationships with 120 mutual fund & annuity firms, was a key presenter on the Raymond James mutual fund platform and helped create, develop and implement their new tiered revenue sharing program.