Survival of the Fittest:

Compliance Program Evolution

Four stages of Compliance

Program Maturity 

As all compliance programs continuously evolve, how do you measure your success or plan for the next step in the development of your program? This video discusses the Four stages of the compliance program maturity model. This model is designed to help you track and communicate your current state as well as pinpoint the places where your program can level up including governance, risk, process, culture, and design.

Ann Oglanian

Ann Oglanian has more than 25 years’ experience in the investment management industry and is sought after for her practical guidance on strategic business planning, organizational and operational matters, and compliance program development and assessment. Prior to founding ReGroup in 2002, Ann served as managing director, general counsel, and chief compliance officer of Montgomery Asset Management and partner in the investment management practice of Vedder Price.

 You can download a full copy of the slides from this webinar.



 Full video transcript availble below

I'm just going to go back to this. This is our maturity model, again, you're going to start at the bottom of the ... you know, you're going to be reacting as you're moving through the maturity model, you are getting more strategic, and the important thing for me is I want you to give yourselves credit for places where you actually really feel like you're orchestrating, and then it's a little easier to report that maybe there were some places where we're still in stage 1. The places where we're in stage 1 don't matter to us. We don't really think that important, then don't do anything about it. If we believe that, "Gee, we should probably do something about it", this is a way of illustrating this for your team so they can really see it. One of the things that we have found is that, if we go back to slide 16 really fast, showing your team, either your compliance committee or your CEO what the pillars are, and then showing them, here kind of, we pinned the tail on the donkey. Next slide, sorry. There we go.

Here's where we pinned the tail on the donkey and why, and here's what we think we need to do to improve each one of these things. Even though there's a ton of stuff that sits behind it, like under policies and procedures there could be a huge amount of substantive detail that sits there. This is something they will understand, and if I show it them over, and over, and over again, it's hard to argue with the fact that we want to be better, continuous improvement. That's part of what we've now set as an expectation, and we've educated people about what we believe the pillars of good design are, so we want to see, and everybody's competitive in our industry. We want to see those color boxes laid in and growing over time. What's nice is you can also just like literally write into the box itself, "This is what we did to move from level 1 to level 2", and you can just report it that way over time, and it's a really simple tool. Very effective.

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