Compliance
One standard for every company.
Dark Ice Management plans to register with the SEC as an investment adviser, with Dark Ice Ventures and Dark Ice Capital as relying advisers. Every Dark Ice company already works to that standard.
Registration
Umbrella registration, one filing adviser.
Umbrella registration.
Filing adviser
Dark Ice Management LLC plans to register with the SEC and serve as the filing adviser.
Relying advisers
Dark Ice Ventures LLC and Dark Ice Capital LLC operate under that registration as relying advisers.
In the meantime
Dark Ice Ventures LLC relies on the venture capital fund adviser exemption as an exempt reporting adviser, and no Dark Ice Capital fund is offered until the registration is effective.
Fund design
Every Dark Ice Ventures fund is designed as a venture capital fund under Rule 203(l)-1, which keeps the exemption available during the transition.
From day one
Marketing, custody and audit, books and records, privacy and code-of-ethics rules are followed now, not later.
The program
One manual and one set of policies for every company and fund.
What the manual covers.
Allocation
One vertical per company: each investment goes to the one Dark Ice Ventures vertical whose lane covers its main product; control buyouts go to Dark Ice Capital.
One vertical
Code of ethics
Personal trading, pre-clearance, gifts and entertainment limits, outside activities and political contributions, on a fixed calendar.
All staff
Marketing review
Every public document, deck and web page is reviewed and cleared before use, under the SEC marketing rule.
Before use
Custody and audit
Each fund is audited annually and its financial statements are delivered to investors.
Annual
Valuation
A written valuation policy, outside valuation above set thresholds and a restatement rule for errors.
Quarterly
Conflicts
Arrangements between Dark Ice companies and funds above set thresholds go to the Advisory Committees concerned.
Committees
Books, records and privacy
Books and records to the registered-adviser standard; investor information protected under Regulation S-P.
Always
Continuity
A business continuity plan and a technology standard for every office and system.
Tested
Lanes
Who invests in what.
Clear lanes.
Dark Ice Ventures
Minority venture investments in private companies, through 44 vertical funds and cross-vertical vehicles.
Venture
Dark Ice Capital
Control buyouts, growth equity, and the businesses and real assets its eight platform companies build and operate.
Private capital
Boundary cases
Anything in between is decided by the Chief Compliance Officer under the allocation policy, with the reasons recorded.
The CCO
The officer
One CCO, employed by Dark Ice Management.
One officer.
One Chief Compliance Officer serves the whole platform, employed by Dark Ice Management and with authority across every Dark Ice company. Until the permanent officer is hired, an outsourced compliance firm serves as interim CCO.