"Hedge Funds" and "compliance" are words most Hedge Fund Managers don't want to hear in the same sentence. Yet last year a SEC mandate completely transformed the regulatory environment of Hedge Funds. As of February 2006, Hedge Fund Advisors were obliged to comply with SEC Rule 203(b)(3)-2 requiring Hedge Fund Advisors to register with the Commission under the Investment Advisors Act. In accordance with the 'written communications' rules under the Act, Hedge Funds were advised to retain all internal and external email and IM business communications.

A recent US Court of Appeals decision overturned this ruling; however mandatory compliance for Hedge Funds appears inevitable. Christopher Cox, Chairman of the SEC, asserts that "hedge funds are not, should not be, and will not be unregulated."

Global Relay's Message Archiver, Compliance Reviewer, Message Converter and IM Interpreter are specifically engineered to provide a total compliance solution and mail management solution for Hedge Funds in connection with electronic business communications, including:

1. Recordkeeping
2. Supervision
3. Audits

The Message Archiver, Global Relay's message archiving and compliance system, captures and archives an authentic and complete record of all electronic business communications in a secure but easily accessible offsite storage system. Compliance features include:

• Message Capture of email, attachments, IM & Bloomberg®
• Archives messages for 5 year SEC term (or as defined by deletion policies)
• Access includes web-based instant access for all employees to their messages
• Tamperproof protection of data on dedicated WORM (Write Once, Read Many)
• Offsite, mirrored, single instance storage in East/West Coast Data Centers
• Indexes & serializes messages, Bcc & Distribution Lists, metadata & audit trails
• Search & retrieval of any message in seconds using Google-like search engines
• Security & encryption of systems, networks & messages
• Migration of legacy data (.pst files, backup tapes) & to archive with new messages
• Retention Term flexibility for Litigation Holds & SEC investigations

How does the Message Archiver work? All email, attachments, Bloomberg and IM and are securely captured and centrally unified together with imported legacy email and .pst files, in Global Relay's Message Archiver for rapid online search, retrieval & monitoring. With secure web-based access and real-time indexing powered by search engine technology, every employee and Compliance Officer has the ability to find any current or historical message in seconds. Read More »

The Compliance Reviewer, Global Relay's monitoring system, provides Hedge Funds with a turn-key, flexible, online supervisory system with advanced monitoring, filtering and eDiscovery features enabling enforcement of your firm's email & IM policies for compliance, proper usage and corporate governance. Compliance features include:

• Scan & Monitor email, attachments, IM & Bloomberg from online Archiver
• Content Filtering with company-defined rules to identify prohibited content
• Advanced Analysis with Boolean logic, criteria lists, proximities & action alerts
• Random Sampling of each employee's messages customized by percentage & user
• Keyword Search results are highlighted within the message for quick discovery
• Full Review of messages & attachments, or bulk review of headers only
• Reviewer approval, rejection, escalation based on action icons & defined notes
• Multi-tiered Review structure for review escalation to Super Reviewers
• Wizard Commands for pre-defined, single-click compliance using folders, flags, priorities & labels
• Exclude Words, phrases or email accounts (e.g. disclaimers, attorney-client privileged mail, newsletters) from Flagging Rules
• Access Rights of authorized Reviewers governed by customized security rules
• Notifications of compliance violations by email or IM
• Audit Trail with detailed time history of reviews and related actions taken
• Web-based Control Center to modify surveillance & monitoring procedures

How does the Compliance Reviewer work? Using powerful search engines, the Compliance Reviewer is able to retrieve your firm's messages from the Message Archiver and apply easy-to-use, company-defined filters and Wizard Commands for efficient review and monitoring of all archived email, IM, and Bloomberg messages. Messages of any user are analyzed on import and flagged for review if violations are detected as follows:

1. real time filtering for keyword or phrase violations (start-up list provided)
2. specific query using flexible search criteria
3. advanced rule-based keyword & phrase proximity analysis
4. random sampling (by User, User Group, or firm-wide, using percentages).

Read More »

Global Relay's Message Archiver & Compliance Reviewer Audit Tools are designed to facilitate efficient responses to regulatory audits and evidentiary requests. Global Relay has successfully assisted hundreds of SEC-regulated firms during their audits and regulatory investigations. Currently, Global Relay participates in approximately 3 to 6 customer audits per week.

• Search & retrieval of any message in seconds using Google-like search engine
• Audit Request response within minutes using online search and eDiscovery tools
• Statistics & reporting on Compliance Officer reviews & related actions taken
• Retention Term flexibility for Litigation Holds & anticipated SEC investigations
• Legal Compliance in-house specialists to assist during audits
• Case Management via folder system with shared folders (e.g. external attorney review)

How do Global Relay's Audit Tools assist with an Audit? Global Relay provides flexible and efficient methods to produce records according to the specific criteria of the audit request. Messages are made readily available for examination either by:

1. Online review of messages via an "auditor account" in Message Archiver

• create online search parameters based on Audit request
• restrict access to the exact scope of the audit (by date, user, subject etc.)
• assign Auditors temporary online review privileges
• block attorney-client privileged, personal or restricted messages
• generate an automatic audit trail of Auditor's review (ie: audit the Auditor!)
• side benefit of data no longer in Auditor's possession once audit is complete

2. Compilation of data for delivery to SEC/FINRA

• fast discovery, consolidation and organization of data for export & delivery
• compile requested information on regulator-qualified media such as DVD or CD

What are the Email & IM Compliance Requirements for Hedge Funds?

What are the repercussions of non-compliance?

Who must comply?

Where can this Legislation be found?