Starting an Alternative Fund Series – Regulatory Compliance Audits- What you Need to Know (Part 4)

Richard’s practice focuses on registration and compliance matters for exempt market dealers, investment fund managers and portfolio managers. He conducts registration analyses, helps firms and individuals navigate the process of becoming registered or obtain exemptive relief where appropriate, engages with regulators on clients’ behalf, and provides advice on registrants’ ongoing obligations and how to deal with securities regulators’ expectations.
Building on his studies in information systems and technology (IT), Richard has gained substantial experience advising registered firms on cyber-security, privacy and anti-spam (CASL) matters. He also helps them develop and test the effectiveness of cyber-security policies and procedures, incident response plans, and cyber-security risk management charters designed to meet securities regulatory requirements.
In addition, Richard has experience assessing the effectiveness of clients’ anti-money laundering (AML) compliance systems and conducting “mock” audits to help clients prepare for regulators’ compliance reviews. He also assists clients undergoing regulatory compliance reviews and has participated in engagements where AUM Law has been approved by the Ontario Securities Commission (OSC) as a compliance consultant in connection with a registrant’s remediation of compliance deficiencies.
Richard also has experience drafting, reviewing and updating firms’ compliance manuals, policies and procedures, including provisions dealing with social media, elderly and vulnerable investors, customer complaints, and whistleblowing. In addition, he has helped clients navigate the complaint process operated by the Office of the Ombudsman for Banking and Investment Services (OBSI).
In addition to his regulatory and compliance practice, Richard has participated in the formation of investment funds and the provision of advice on the legal and regulatory implications of offering and distributing securities of such funds in Canada.

PROFESSIONAL BACKGROUND
Davies Ward Phillips & Vineberg (2010–2011)

BAR ADMISSION
Ontario, 2011

EDUCATION
JD, Queen’s University, 2010
BComm, McGill University, 2006

David Jarvis – President, Chief Executive Officer, Portfolio Manager of Corton Capital Inc.

David Jarvis is the founder and one of the principals of Corton Capital Inc. and acts as the firm’s Portfolio Manager. From September 2017 to September 2018, Mr. Jarvis, was the President and Director of Kaleido Capital Ltd. From October 2015 to September 2017, Mr. Jarvis was the Chief Compliance Officer of Forge First Asset Management Inc. where he was primarily responsible for compliance and risk management. While at Forge First, David developed enhanced compliance systems, designed and ran “mock” compliance audits and developed internal risk management guidelines addressing key risk areas – market risk, liquidity risk and credit risk. From 2005 until September, 2015, Mr. Jarvis was a founding partner, Chief Financial Officer, Chief Compliance Officer and a Portfolio Manager of Spartan Fund Management Inc. During his tenure with Spartan, David conceived, designed and co-built the first hedge fund platform in Canada with over 15 funds, portfolio managers/traders/analysts including funds based in Canada and the Cayman Islands. At Spartan David worked closely with each fund group and customized compliance and risk management programs for each type of fund style. During his time with Spartan, the Spartan Multi Strategy Fund LP received Morningstar’s Gold Medal for Best Multi Strategy Fund (Canada) in 2011 after winning the Silver Medal in 2010.

David has also been a Director and Chair of the Audit Committee of Leviathan Cannabis Group Inc. (CSE: EPIC) since November 2018. Leviathan is a publicly traded cannabis company focused on creating brand loyalty while building medical and recreational distribution channels for hemp derived products. Since March, 2010, David has also provided expert witness reports and analysis from time to time in relation to compliance and operations for brokerage and asset managers dealing with such matters as suitability, “know your client”, disclosure obligations, and institutional operational practices. In this capacity, David has been retained by retail investors, institutional clients, and several law firms.

David played an important role in the establishment of the Canadian chapter of the Alternative Investment Management Association (AIMA Canada) and served as the organization’s first Vice-Chairman from 2003 – 2005. David also served as an active member of the Practices & Standards Committee and the Compliance Officers’ Network, 2016 – 2018, of the Portfolio Management Association of Canada (PMAC).

David holds a Chartered Financial Analyst (CFA) designation and has an MBA (Queen’s University) and an Hons. BA – Economics (University of Western Ontario).

James co-founded CAASA in response to industry support for a Canadian alternatives association to serve all aspects including: hedge / alternative strategies; private lending; private real estate; private equity; plus emerging areas where Canada is a leader such as digital assets / blockchain and robo-advisors.

Prior to CAASA, James was the Chief Operating Officer of AIMA Canada where his team of three worked with 12 committees to produce 50-60 events per annum across Canada, organize 100+ committee meetings, and increase member numbers over his 7-year tenure from 66 to 164 corporate entities.

James also has experience in research and writing for the CAIA Association as well as serving on CAIA’s Exam Council and as a grader for the Level II portion of the exam.  He also had roles in institutional sales and FoHF structuring in Seoul, South Korea, as a Product Manager at ICICI Wealth Management, and an Investment Advisor at RBC Dominion Securities.  He graduated from Simon Fraser University with a BBA (Finance).