Frequently Asked Questions | PINE Advisor Solutions

Answers at Your Fingertips - PINE's FAQ Hub

Have questions? We’ve anticipated them. Our FAQ Hub is a reservoir of clarity, offering you immediate answers to common inquiries about PINE Advisor Solutions. Whether it's a query about our services, the specifics of operational support, or how to begin your journey with us, find your solutions here. It’s our commitment to transparency and guidance at every step, ensuring that your path to partnering with PINE is as straightforward and informed as possible.

Distribution Services

What Distribution Services does PINE offer?

Through its limited purpose broker-dealer entity PINE Distributors LLC, PINE can provide a suite of legal underwriter and principal distributor solutions to mutual funds, closed-end funds, and ETFs, as well as placement marketing support for private fund sponsors.

What does it mean to be a limited purpose broker-dealer?

PINE Distributors LLC is a limited purposed broker-dealer, as such the firm (including its registered representatives) acts solely in a wholesaling capacity and does not: • offer investment advice • open or maintain shareholder accounts • custody shareholder funds for investment • process shareholder purchase, redemption, or exchange orders

How does an adviser know what distribution services their fund might need?

The PINE team will conduct an extensive review and facilitate discussions with an adviser and other service providers to a fund. Together we will identify the most appropriate range of services, including; named statutory distributor, registered representative licensing, advertising & sales content review, intermediary contract management & oversight, intermediary fee administration, and ETF solutions.

Does an adviser firm need to be a FINRA member to manage a 1940 Act registered investment company?

No - when PINE Distributors LLC provides distributions services to a fund, we act as the legal underwriter, also referred to as principal underwriter or distributor. To provide these services, PINE Distributors LLC will maintain its required registration as a broker dealer with the SEC under the Exchange Act, as well as its membership of FINRA.

Can an adviser enter into a distribution agreement with PINE Distributors LLC for a fund that it sponsors?

While the adviser of a fund can recommend that PINE Distributors LLC acts as distributor, this is subject to review and a “15(c) approval” by the fund board of directors. PINE will provide full support for the review and approval process, including creating a detailed 15(c) response for board consideration.

Can adviser employees hold FINRA licenses with PINE?

Yes, employees of advisers to funds that PINE provides distribution services to may be registered representatives of PINE Distributors LLC. This is subject to individual qualification, as well as agreement to follow PINE Distributors written supervisory procedures and for a registered individual’s distribution related activities to be supervised by PINE Distributors.

What are PINE Distributors LLC ETF Solutions?

In addition to standard Distribution Services, PINE can provide additional ETF-specific solutions such as an authorized participant agreement management process, and an authorized participant order desk.

Can PINE provide distribution services to registered closed-end funds?

Yes, PINE can provide customized services to most registered pooled-investment vehicles, including closed-end funds such as tender-off and interval funds.

Adviser Compliance Support Services

What compliance services does PINE offer to investment advisers?

PINE offers a wide range of compliance support services tailored to investment advisers. This includes becoming the outsourced CCO, providing staff to support your in-house CCO, helping firms register as an RIA or make transitions between regulatory regimes, launching new pooled investment vehicles, and ongoing compliance program management.

How does PINE customize services for each adviser?

PINE employs a risk-based approach and conducts a thorough risk assessment of each adviser to understand their specific business activities and risks. Based on this, PINE develops customized policies, procedures, manuals and trainings to build a compliance program tailored to their needs.

When should an investment adviser engage PINE for registration transitions and new registration?

PINE can assist investment advisers with transitions between all regulatory regimes including state to SEC registration, SEC to state registration, transition from Exempt Reporting Adviser ("ERA") status to Registered Investment Adviser ("RIA"), and registering as a new RIA. The ideal time to engage PINE is at the beginning of your transition or registration process so we can manage the entire process including drafting documents, filing paperwork, updating compliance programs, training staff, and ongoing support. However, PINE can provide specialized compliance expertise and support at any stage of the transition or new registration process.

Does PINE provide an outsourced CCO option?

PINE can serve as the outsourced CCO for select firms that want dedicated CCO support without having to hire internally. This involves taking on the full responsibilities of CCO including managing the compliance program, regulatory filings, examinations, and more.

How does PINE stay current on changing regulations?

PINE actively monitors regulatory changes, regularly updates policies and procedures, and provides ongoing staff and client training on new rules to remain up-to-date.

What expertise does PINE offer for pooled investment vehicles?

PINE has specialized expertise in compliance for pooled vehicles like mutual funds, ETFs, and private funds. PINE can assist with launching new vehicles, managing ongoing compliance, and staying current on related regulations.

Private Fund Chief Financial Officer

What assistance does PINE offer to new private fund managers?

PINE assists new private fund managers with all operational aspects of setting up their fund. We can make introductions to industry leading audit and tax, banking, broker and administration service providers to make sure you find the best fit for your fund. We then will assist with all setup requirements needed with each service provider to get your fund up and running.

What services does PINE offer with management company oversight?

PINE offers a wide range of management company oversight services. This can include monthly bookkeeping, preparing monthly financials statements and budget-to-actual reports, assist with paying all management company expenses, completing 1099 filings at year end and more.

What type of private funds does PINE provide CFO services for?

We can provide CFO services for any type of pooled investment vehicle. We have experience and specialized expertise in open-end, closed-end, and hybrid funds that invest in a wide range of asset classes. We are product wrapper and asset class agnostic and can tailor our services to fit the needs of any type of pooled investment vehicle, including hedge, private equity, special purpose vehicles and fund of funds.

What are the core services performed by PINE for private fund fractional CFO services?

PINE can perform all back office, operational, finance, accounting, and non-investment functions for a pooled investment vehicle. Our core services can include oversight of the fund administrator and dual reviews of the monthly or quarterly NAV and investor statement reporting, processing of fund expenses, oversight, review, and facilitation of the yearly tax and audit processes, coordinating the setup of the fund and service providers, review of fund formation documents, and much more. PINE can offer services tailored to the needs of any client.

Registered Fund Officer Solutions

What services does PINE offer through its Fund CCO Services program?

PINE’s experienced Fund CCOs provide integral compliance support for your registered funds, including the review or creation of a customized compliance program, ongoing testing of compliance policies and procedures, quarterly monitoring and annual due diligence of service providers, monitoring and implementation of regulatory changes and quarterly and annual 38a-1 reporting to Fund Boards. PINE’s Fund CCOs do more than just meet Regulatory requirements and are empowered to be a trusted partner to clients, service providers and Fund Boards.

How does PINE handle regulatory changes?

The PINE CCO team proactively addresses regulatory changes through a comprehensive approach that includes monitoring, impact assessment, customized policies, training, testing, ongoing support and documentation. This approach ensures our clients remain compliant, reduce risks, and stay focused on their core business objectives amidst evolving regulations.

In the event of an SEC examination, what support can we expect from a PINE Fund CCO?

Our Fund CCOs design each Fund Compliance program in anticipation of regulatory examinations. During an exam, PINE’s Fund CCOs will serve as the point of contact for the SEC and will assist in gathering and reviewing documentation from the applicable service providers. The PINE Fund CCO will guide your team through the examination process to ensure a smooth and compliant experience.

How do PINE and the Fund CCOs stay up-to-date with the ever-changing regulatory landscape?

PINE maintains a dedicated team of compliance experts who closely monitor regulatory changes, attend industry seminars, monitor the websites of Regulators, review legal bulletins, and engage in ongoing training. PINE’s Fund CCOs proactively address these changes utilizing a comprehensive approach that includes an impact assessment, creating customized policies, testing, and providing ongoing support and documentation. This approach ensures our clients remain compliant, reduce risks, and stay focused on their core business objectives amidst evolving regulations.

How does PINE maintain oversight over service providers?

PINE’s Fund CCOs oversee applicable service providers through an established process of quarterly questionnaires, certifications, monitoring performance and conducting detailed due diligence. PINE’s Fund CCOs strive to maintain collaborative communication channels and work with each service provider to implement escalation protocols that are the keys to a successful relationship.

What sets PINE apart from other compliance service providers?

PINE stands out due to our tailored approach, experienced team, and commitment to personalized service. Our Fund CCO’s work closely with you and the board members to understand your unique needs, providing proactive compliance solutions and ongoing support, which ensures your fund remains compliant while optimizing its operational efficiency.

Can PINE assist with the considerations of a transition from managing private funds to managing a registered fund?

There are many regulatory differences between managing a private fund versus a registered fund that need to be considered when contemplating this transition, and our experienced PINE team can assist with that process.

How can PINE help me navigate the regulations and rules of a registered fund?

PINE offers a team of experienced industry professionals who can help you monitor and work through the regulatory considerations of launching and managing a registered fund. A PINE PFO will assist with the certification and disclosure controls processes required for a registered fund’s financial statements, regulatory and shareholder reporting.

What are the challenges of a registered fund investing in private funds and how can PINE help?

One of the largest challenges is acquiring information from underlying managers. Registered funds have IRS diversification, distribution and reporting requirements. A PINE PFO can assist you in monitoring these requirements and providing guidance on obtaining the correct information to ensure your fund stays within compliance of these rules.

Can PINE provide recommendations and guidance regarding the launch and set up of my Fund?

PINE has a team of professionals that have vast experience in the finance industry. A PINE PFO can help you review the regulatory requirements and provide guidance alongside counsel and fund administrators to work through any issues or questions that arise during the launch or ongoing operations of your fund.

Does it matter what month I choose for my fund's fiscal and tax year ends?

Depending on the investment objective of your fund, yes. If your fund's underlying investments will be issuing audited financial statements and K-1s, you'll want to align your fiscal and tax year ends so you receive these documents with enough time to incorporate the necessary information into your annual audits and tax returns.

What are the requirements for a registered fund’s Principal Financial Officer/Treasurer?

The Principal Officer/Treasurer must be approved by the fund’s Board of Trustees and should be knowledgeable of the 1940 Act. The Sarbanes-Oxley Act of 2002 and the 1940 Act require Certifying Officers to make certain certifications on each periodic report containing financial statements. PINE offers a team of PFOs with strong backgrounds who can fulfill these requirements.

Operations Support Services

What types of operations support does PINE offer?

PINE provides end-to-end investment operations support including trade capture/allocation, internal/client reporting, reconciliations, trade settlement, performance tracking, process documentation, and more.

How does PINE tailor operations services for each client?

PINE takes the time to understand each client's unique operations infrastructure, strengths, challenges and needs. We then customize a solution and workflow that allows the client to focus on their core strengths while we handle operations support.

Does PINE ever fully rebuild or replace processes or infrastructures?

While PINE strives to work within existing operations infrastructures to improve efficiencies over time, we can conduct full rebuilds if needed. PINE has the capabilities to implement entirely new processes, technologies, and systems tailored to a client's needs.

What benefits does PINE's operations support provide?

By leveraging PINE's operations support, clients can reduce manual processes, minimize risks, create efficiencies, and dedicate more resources to core business activities. This enables clients to improve operational performance, scale more efficiently, and focus their efforts on revenue-generating activities to grow their business.