The document provides an overview of the services offered by Accounting & Compliance International (ACI). ACI offers accounting, bookkeeping, financial reporting and compliance services for broker dealers, investment advisors, hedge funds and other financial firms. Their services include accounting, bookkeeping, regulatory filings, compliance program development and reviews, and ongoing compliance support and consulting.

1. comPlYing With regulAtorY requirements
shoulD Be Business enhAncing, not hinDering
Accounting, FinoP & comPliAnce services
AccountABilitY is the neW gloBAl stAnDArD.
Accounting & compliance international
Your Passport to security
www.acisecure.com

2. comPAnY overvieW
Accounting, FinoP & BookkeePing
Broker DeAler comPliAnce
heDge FunD & riA comPliAnce
contAct us
theY’re looking At
You through A
mAgniFYing glAss.
Are You PrePAreD?
Accounting & compliance international • 40 Wall st, 34th Floor • new York, nY 10005 • 212-668-8700 •info@acisecure.com

3. comPAnY overvieW
Aci comPAnY overvieW
Aci believes that complying with regulatory
requirements should be business enhancing, not
business hindering. By developing tailored programs for
our clients that account for the individual risks of the
firm relating to size, strategy, structure, and business
practices, Aci is able to create and maintain cost
effective business and regulatory programs that will
withstand the scrutiny of regulators, auditors, and
investors. Aci’s consulting programs are supported by
more than 25 years of expertise within the financial
industry. Design and maintain your compliance and
accounting programs with Aci.
our clients incluDe
•Broker Dealers •investment Advisers
•hedge Funds
corPorAte heADquArters
40 Wall st, 34th Floor, new York nY 10005
regional representatives throughout the usA
AreAs oF exPertise
Accounting, BookkeePing & FinoP comPliAnce services
Accounting services: registration
• Bank reconciliations •new membership Applications
• Bookkeeping •continuing membership Applications
• Brokerage statement Analysis •1017 Additional lines of Business/material change
• Financial statement Preparation •membership Withdrawals
• net capital computations •u4 / u5 Filings
• Focus reporting •Form ADv Part i and ii
• FinoP outsourcing compliance Documents & infrastructure
• FinrA examination support •compliance manuals/code of ethics/Privacy Policy
• entity/Personal taxation •Business continuity Plans
• Accounting Due Diligence •Aml Procedures
Audits & reviews
Aci specializes in Broker Dealer Accounting, but additional •Aml Audits
capabilities include corporate accounting for small to •supervisory controls review & ceo certification
medium sized businesses such as law firms, corporate •Advertising and marketing reviews
real estate companies, architectural firms, and high •Brokerage statement reviews
•email reviews
net-worth individuals.
•Due Diligence
•Annual compliance meeting
•internal inspections
•osJ and Branch office examinations
•mock sec/FinrA Audits
consulting support
•onsite and telephone consulting
•exam Preparation and checklists
•onsite exam management
•regulatory comment letters & inquiries
•Arbitration and litigation support
•sec Filings
Accounting & compliance international • 40 Wall st, 34th Floor • new York, nY 10005 • 212-668-8700 •info@acisecure.com Page 1

4. Accounting, BookkeePing & FinoP services
BAnk reconciliAtions
Accounting outsourcing Aci exercises care in reconciling bank accounts on a monthly
basis. Access to online bank statements ensures that Aci can
reconcile bank accounts early in the month and provide
Aci has over 25 years of experience handling
accurate bank balances to the client at all times.
the full range of accounting services for
financial industry clients. While specializing in BookkeePing
broker dealer accounting, Aci also works with Aci provides full-scale bookkeeping services. each client is
other small to medium sized businesses to assigned a primary and secondary bookkeeper to record all
provide accounting and bookkeeping services. receivables, analyze and record invoices into accounts payable,
cut checks and process payroll.
We provide oversight and accurate reporting BrokerAge stAtement AnAlYsis
for our clients regarding all accounting matters. introducing broker dealer firms that are unable to clear their
own trades often opt to clear their trades through larger firms.
Accounting outsourcing services Aci is familiar with the statements generated by most clearing
• Bank reconciliations firms and is trained to accurately analyze & reconcile these
• Bookkeeping accounts.
• Brokerage statement Analysis FinAnciAl stAtement PrePArAtion
• Financial statement Preparation Aci produces accurate and timely financial statements for all
• net capital computations end users, inclusive of a balance sheet, income statement and
• Focus reporting general ledger detailing all monthly activity. reports are
• FinoP outsourcing provided to the client within 17 business days of month end,
• FinrA examination support as required by FinrA.
• entity/Personal taxation net cAPitAl comPutAtions
• Accounting Due Diligence Aci prepares monthly net capital computations and provides
guidance as to whether or not to infuse additional capital to
avoid regulatory violations. net capital computations can be
performed during the month if net capital deficiencies are
anticipated.
Focus rePorting/FinoP
sec rule 17a-5 requires all broker dealers to file monthly/
quarterly Focus reports. Aci has earned a reputation as the
premier provider of Focus reporting for new York stock
exchange member firms. Aci employees can also serve in the
FinoP capacity, often saving clients a significant cost burden.
Accounting You cAn A Financial operations Principal is required for all direct access
broker dealer firms regulated by FinrA.
count on to Be AccurAte.
FinrA exAminAtion suPPort
FinrA conducts an annual review of each member firm to
ensure the accuracy & fairness of the financial statements
being reported. As the provider of accounting services, Aci
prepares all documents required to perform the review and
works with the examiners to answer any financial questions.
entitY/PersonAl tAxAtion
Aci prepares and files federal, state, and city entity tax returns
for our accounting clients to ensure precision and accuracy in
tax planning. We also file hundreds of individual returns for
both owners and employees of the clients we service.
Accounting Due Diligence
Aci will review the accounting history and records for potential
broker dealer purchases to ensure the firm has previously
maintained compliance with FinrA regulations.
Page 2 Accounting & compliance international • 40 Wall st, 34th Floor • new York, nY 10005 • 212-668-8700 •info@acisecure.com

5. Broker DeAler comPliAnce
Broker DeAler comPliAnce registrAtions & WithDrAWAls
Aci provides consulting support to determine the best
course of action when looking to start or close a broker
Aci provides compliance consulting services for dealer firm. We can work with your firm to execute on a
broker dealers to ensure that they are compliant new membership Application, 1017 change in ownership
with applicable rules and regulations of FinrA, the Application, or Withdrawal
sec, or any other regulatory body that governs Application. Aci also assists with filing u4 and u5 forms
their business. for registered representatives.
Broker Dealer compliance consulting services
comPliAnce Documents & inFrAstructure
registrations & Withdrawals Aci works with clients to tailor the firm’s written
•new membership Applications supervisory procedures, code of ethics, privacy policy,
•continuing membership Applications business continuity plans and Aml procedures to create
•1017 Additional lines of Business/material change a supervisory structure that accounts for each unique
•membership Withdrawals business model. Aci can develop this infrastructure with
•u4 / u5 Filings your firm as well as provide maintenance if and when the
compliance Documents & infrastructure infrastructure has been established.
•compliance manuals/code of ethics/Privacy Policy
•Business continuity Plans AuDits AnD revieWs
•Aml Procedures Aci’s compliance professionals guide your firm through the
Audits & reviews appropriate compliance review program to identify and
•Aml Audits improve weaknesses and deficiencies. At the end of a
•supervisory controls review & ceo certification review, Aci provides the client with a verbal summary of
•Advertising and marketing reviews findings as well as a written report with recommendations.
•Brokerage statement reviews these reviews include:
•email reviews Aml AuDit
•Due Diligence Aci writes Aml prevention procedures to detect
•Best execution suspicious securities transactions and conducts the Aml
•Annual compliance meeting / continuing education audit.
•internal inspections
•osJs and Branch office exams suPervisorY controls revieW
•mock sec/FinrA Audits Aci conducts a gAP Analysis of the written supervisory
procedures against firm practices and provides
consulting support
recommendations on areas that would be enhanced by
•onsite and telephone consulting
updates.
•exam Preparation and checklists
•onsite exam management ADvertising & mArketing revieWs
•regulatory comment letters & inquiries Aci reviews materials and consults on required changes.
•Arbitration and litigation support
•sec Filings Due Diligence
Aci oversees due diligence reviews for our clients.
AnnuAl comPliAnce meeting /continuing eDucAtion
Aci can assist your firm with holding the annual
compliance meeting and developing and implementing
other continuing education programs.
internAl insPections/ osJ AnD BrAnch oFFice exAms
Aci conducts inspections of the broker dealer’s home
office and branch office exams to fulfill the inspection
requirement. Aci also conducts mock exams to get your
firm ready for upcoming sec or FinrA Audits.
consulting suPPort
is comPliAnce hinDering Aci can provide monthly compliance and consulting to
keep your firm informed of the latest regulations and
Your Business?
answer any compliance questions or concerns that may
arise within your firm. this could include quarterly onsite
visits, telephone support, assistance with sec filings and
pre/post exam support.
Accounting & compliance international • 40 Wall st, 34th Floor • new York, nY 10005 • 212-668-8700 •info@acisecure.com Page 3

6. heDge FunD & riA comPliAnce
investment ADvisor registrAtion
heDge FunD services sec registration
•Preliminary Business consult to advise the client
•Preparation and filing of Form ADv Part i
Aci remains cutting edge with the latest •Preparation of iArD entitlement forms for electronic filing
regulatory changes and develops speciality •Development (or review) of
programs that meet those regulations while o Policies and Procedures
keeping your firm competitive and focused on o code of ethics
business growth. o Privacy Policy
o schedule F
hedge Fund and riA compliance Programs • Preparation Form ADv Part ii/the Brochure
• investment Advisor registration: sec/state state registration(s)
• compliance infrastructure Development •customized based on Blue sky laws for each state
o Aml procedures
comPliAnce inFrAstructure DeveloPment
o Business continuity Plan
Aci assists your firm to develop a streamlined compliance
o code of ethics
program that makes the best use of both internal and external
o Policies and Procedures
resources. services may include:
o Privacy Policy
• Development of integral compliance documents:
• Documented compliance reviews & Audits o Aml Procedures
• compliance continuity checks o Business continuity Plan
o Pre/Post exam services o code of ethics
• compliance outsourcing o Policies and Procedures
o ongoing compliance o Privacy Policy
o quarterly compliance • Development of an implementation plan
o Annual compliance • Development of an annual compliance calendar
• compliance training
• quarterly onsite visits and telephone access to an Aci
consultant for consulting support
DocumenteD comPliAnce revieWs AnD AuDits
Aci recognizes the pressure placed on funds by investors who
are seeking consistent messaging and greater transparency.
Aci works with your firm to conduct a series of reviews and
reports to share with your investors.
• Advertising & marketing reviews
• Annual review / quarterly reviews
• code of ethics reviews
• Due Diligence reviews
• Form ADv review and Annual update
• mock sec exam + Findings report
comPliAnce continuitY checks
• Aci can conduct a risk Assessment of your existing
compliance program to discover and rectify gaps and
inconsistencies between procedures and practices in key risk
areas.
We can also update procedures to develop processes that will
minimize operational risks
• sec exam Preparation including provision of document
Are You AheAD oF the request lists and checklists
• mock sec exams to familiarize your firm with the
lAtest regulAtions?
examination process
•Post-sec exam support to respond to comment letters
Page 4 Accounting & compliance international • 40 Wall st, 34th Floor • new York, nY 10005 • 212-668-8700 •info@acisecure.com

7. contAct us
heDge FunD & riA comPliAnce outsourcing Welcome to the neW WorlD
Aci can work with the cco to oversee the implementation of your oF regulAtion
compliance program. maintaining a compliance program can be a
daunting task for a cco or even a team of compliance professionals.
For ongoing support in maintaining your existing compliance
program, Aci can assist in the following areas:
ongoing support
• telephone support for the firm’s cco and staff
• Assist client in setting up an automated personal trading platform,
if deemed necessary based on size and trade volume, for
automated pre-clearance
• review of employee emails
• review of advertising & marketing materials as needed
• Development of an annual compliance calendar (based on firm
policies with reminders to conduct tasks)
quarterly on-site reviews
• quarterly on-site review of the compliance program contAct us
• training programs for compliance staff, management and
employees to facilitate compliance implementation
• review and update of code of ethics, privacy policy and policies
and procedures
Annual requirements and updates
• Assist with Form ADv Part i and ii updates
• Assist with sec Filings
• Due Diligence review of investors, service providers and related Aci - Accounting & comPliAnce
companies internAtionAl
• review of offering documents, disclosures and applicable 40 WAll street, 34th Floor
schedules neW York, nY 10005
• Aml Audit (if Aml procedures in place) FAx: 917 591-1440
• Annual review Phone: 212-668-8700
emAil: inFo@Acisecure.com
Accounting & compliance international • 40 Wall st, 34th Floor • new York, nY 10005 • 212-668-8700 •info@acisecure.com Page 5

8. contAct
Accounting & comPliAnce internAtionAl
40 WAll street, 34th Floor
neW York, nY 10005
FAx: 917 591-1440
Phone: 212-668-8700
emAil: inFo@Acisecure.com
Accounting outsourcing services comPliAnce outsourcing services
• Bank reconciliations registration
• Bookkeeping •new membership Applications
• Brokerage statement Analysis •continuing membership Applications
• Financial statement Preparation •1017 Additional lines of Business/material change
• net capital computations •membership Withdrawals
• Focus reporting •u4 / u5 Filings
• FinoP •Form ADv Part i and ii
• FinrA examination support
• entity/Personal taxation compliance Documents & infrastructure
• Accounting Due Diligence •compliance manuals/code of ethics/Privacy Policy
•Business continuity Plans
•Aml Procedures
Audits & reviews
•Aml Audits
•supervisory controls review & ceo certification
•Advertising and marketing reviews
•Brokerage statement reviews
•email reviews
•Due Diligence
•Annual compliance meeting
•internal inspections
•osJ and Branch office examinations
•mock sec/FinrA Audits
consulting support
•onsites and telephone consulting
•exam Preparation and checklists
•onsite exam management
•regulatory comment letters & inquiries
•Arbitration and litigation support
•sec Filings
WWW.Acisecure.com