Black Cypress has established a comprehensive compliance program to demonstrate its commitment to transparency and ethical business practices. The firm’s Chief Compliance Officer oversees the program, which covers two main areas: Global Investment Performance Standards (GIPS®) and regulatory compliance in the states where the firm is registered as an investment adviser.
First, Black Cypress seeks to be transparent and consistent in the way it calculates and presents its performance. Black Cypress claims compliance with the Global Investment Performance Standards (GIPS®). This claim has been independently verified by Ashland Partners & Company, LLP from 10/21/2009 through 12/31/2016 and by ACA Compliance Group from 01/01/2017 through 12/31/2018. Additionally, the firm’s Long-Only Equity Composite has been examined for the periods 03/31/2011 through 12/31/2018. The verification reports and compliant presentations are available upon request to email@example.com or 864-735-8092.
Second, Black Cypress ensures regulatory compliance through the implementation of written policies and procedures in its Compliance Manual. All of the firm’s team members are required to acknowledge and abide by these policies and procedures. The Compliance Manual includes a Code of Ethics, Business Continuity Plan, and Cyber Incident Response Plan.
Black Cypress prides itself on its ability to offer a compliance program that is comparable in sophistication and protection to that of a larger firm while still maintaining the agility and close client relationships of a smaller firm.
Definition of the Firm: Black Cypress Capital Management, LLC (“Black Cypress”) is a state-registered investment advisor (RIA). The firm began managing assets June 30, 2009. Prior to April 2011, the firm managed assets on an advisory-only, non-discretionary, or non-fee-paying basis only. The firm’s list of composite descriptions is available upon request. Black Cypress reviews its total firm AUM by account on a monthly basis to ensure that only actual assets managed by the firm are included. All accounts deemed to be advisory only, hypothetical, or model in nature are excluded from total firm AUM.