CASE STUDY: Del Mar Asset Management ‘‘(SS&C GlobeOp) is our accounting and financial repository, so obtaining the data was straightforward for them.’’ Contained within the 2,319 pages of the Dodd-Frank Act lie Sections 404 and 406, which obligate private funds including hedge funds, private liquidity funds and private equity vehicles managing in excess of $150 million in assets under management (AuM) - to file a Form PF with the United States Securities and Exchange Commission (SEC). The Faced with the cost, risk and administrative burden of completing Form PF, one New York-based fund manager out-sourced the task to its fund administrator. Del Mar Asset Management also expects to use SS&C GlobeOp to assist with FATCA. SEC will subsequently pass all of this data to the Financial Stability Oversight Council (FSOC), the body charged with monitoring systemic risk in capital markets. Del Mar Asset Management, a New York-based multistrategy, event-driven hedge fund with approximately $200 million in AuM, was just one of the 2,661 investment advisers affected by the rule changes to submit Form PF. Del Mar is required to submit Form PF annually as it lies below the $1.5 billion threshold for quarterly reporting. To assist it with filing Form PF, it looked to its fund administrator, SS&C GlobeOp. “The rationale for choosing SS&C GlobeOp to help us with our Form PF submissions are several-fold,” explains Jeffrey Hwang, chief operating officer (COO) at Del Mar. “The fund administrator is very technology-focused and its hedge fund platform and web portal are robust. We also used GlobeOp as administrator prior to its acquisition by SS&C Technologies, and maintaining that relationship ensured we could file our regulatory reports in a seamless and streamlined manner.” The Form PF service from SS&C GlobeOp aggregates While Hwang does not provide specifics on pricing, he requires them to enhance their investor due diligence describes the SS&C GlobeOp Form PF service as “highly and demand proof through a W-8 or W-9 form that an competitive in regards to its peers.” For this reason, unlike investor is not American. Given the wealth of data held other initial Form PF filers, Del Mar elected not to in-source by administrators, many are offering a FATCA compliance the entire process. “We felt confident that SS&C GlobeOp tool, and SS&C GlobeOp is no exception. “While we are had the internal infrastructure and operational know-how and not reporting data under FATCA yet, we are using SS&C knowledge to do it for us right from the offset,” says Hwang. GlobeOp to assist us in FATCA compliance and ensuring our Going forward, Del Mar plans to use SS&C GlobeOp to assist investors are not recalcitrant in any way, or non-compliant it with compliance with the Foreign Account Tax Compliance with US tax law,” says Hwang. Act (FATCA), the United States (US) legislation aimed While SS&C GlobeOp offers reporting services to help at forcing financial institutions (FIs) and foreign financial managers submit their Annex IV under the European Union institutions (FFIs) to disclose information on account-holders (EU) Alternative Investment Fund Managers Directive to local tax authorities and the Internal Revenue Service (AIFMD) and the Open Protocol Enabling Risk Aggregation (IRS) so as to identify any Americans not paying income tax. (Open Protocol), the risk reporting tool kit developed by FATCA is another reporting headache for managers and Albourne Partners, Del Mar is not using those offerings yet. and maps the relevant data for the 3,000-plus data fields demanded by Form PF. One of the biggest challenges fund administrators have is sourcing all of these data sets, many of which may be held by other administrators, custodians, prime brokers and the managers themselves. “The process was smooth,” comments Hwang. “SS&C GlobeOp has nearly all of our books and records in their systems. It is our accounting and financial repository, so obtaining the data was straightforward for them. I believe they SS&C GlobeOp at a glance Contact For further information about regulatory services, please contact: host close to 90 per-cent of our data. The only data we had to Assets under provide was the internal risk reporting.” administration (AuA): 675 Third Avenue $587 billion New York, NY 10017 Number of clients: More than 200 clients use the regulatory services of SS&C GlobeOp Email: [email protected] The SS&C GlobeOp toolkit also gives managers an explanation behind the methodologies it employs in the calculations that populate Form PF. Clients are, however, allowed to provide overrides for responses to questions, and document additional methodologies, during the compilation process. To enable clients to enjoy this transparency, the United States of America Telephone: +1 212 455 6333 www.ssctech.com Mike Megaw Managing director, regulatory solutions, SS&C GlobeOp SS&C GlobeOp Form PF workflow is done via GoCheck, a process management tool that gives clients transparency into the entire process. 168 169
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