The Right Indicators Bring Clarity to Assuring Compliance Oversight

If the first stage of a pragmatic Know Your Risk strategy is deconstructing and understanding compliance obligations to define where you need to keep your focus, the next step is mapping policies, procedures and controls to performance indicators to be able to accurately assure compliance.

Essentially, at this stage, we need to answer the question: What do we actually need to monitor?

Read More

SEC Bulletin Highlights Need for Effective Conflicts Management

The U.S. Securities and Exchange Commission (SEC) recently released the staff bulletin Standards of Conduct for Broker-Dealers and Investment Adviser Conflicts of Interest to reiterate the required standards and obligations for broker-dealers under Regulation Best Interest (Reg BI) and for investment advisers the fiduciary duty standards under the Investment Advisers Act of 1940.

Read More

Data Mapping Effectively Deconstructs Compliance Obligations

Regulations, frameworks, policies and controls define the day-to-day of the Chief Compliance Officer (CCO) and their teams. It’s fair to say that it is an important yet often troublesome undertaking to make sense of what can often be described as monitoring spaghetti. At the same time, the teams also need to ensure they are keeping senior execs and the Front Office engaged and compliant.

So how can the CCO set regulatory priorities, identify policy and procedure gaps and understand compliance obligations?

Read More

SEC Focuses on MNPI and Code of Ethics Issues

The SEC issued the Risk Alert Investment Adviser MNPI Compliance Issues to provide investment advisers, investors, and other market participants with information concerning notable deficiencies that the the Division of Examinations (“EXAMS”) has cited related to material non-public information (MNPI) and Code of Ethics Issues.

Read More

Authority, Ability & Responsibility: Keys to CCO Liability

If you’re in Compliance, you know the crucial role that the Chief Compliance Officer plays in helping to maintain integrity in the securities industry and preventing violations. CCOs’ jobs are challenging enough given the wide range of obstacles they face day to day without having to routinely worry about whether simply carrying out their responsibilities will subject them to personal liability.

Read More