At Spartan, we believe that solid risk management and compliance are one of the cornerstones of any money management business. Our Risk Management Committee, comprised of our Chief Compliance Officer (CCO), Chief Investment Officer (CIO) and our Managing Director, utilizes the following procedures:
- Separation of Duties: we ensure separation of duties between the trading function and the risk management/compliance function by having separate individuals in charge of each function and by having the Chief Risk & Compliance Officer report directly to the President. Externally, we utilize a 3rd party fund administrator to independently calculate the fund’s net asset value, major banks and dealers act as custodian for the assets of the funds that we manage and we also use a nationally recognized auditing firm to independently audit the fund’s financial statements.
- Trading Limits: typically, our funds establish maximum position size for individual securities – often these maximum position limits are less than 5% for any of our funds.
- Operational Risk: we ensure that, amongst other things:
a. all movements of funds require authorization from two senior officers, one of whom is a non-trading officer
b. all trades are tracked by our Chief Risk & Compliance Officer
- Risk Monitoring: our Chief Risk & Compliance Officer:
a. monitors a range of risk factors, including position limits, concentration and margin usage.
b. establishes trading policies that all employees of Spartan must adhere to.
- Regulatory Compliance: registrations, along with all other necessary regulatory requirements including insurance and capital requirements, are maintained by our Chief Risk & Compliance Officer.
- Legal: legal counsel is required to review all documentation before they are signed.
We would be more than happy to discuss our risk policies and the specific trading restrictions and limits that apply to any of our funds at your convenience.