Investment Company Compliance Program and Annual Review
August 2, 2012
1:00 PM – 3:00 PM ET
Rule 38a-1 under the Investment Company Act of 1940 requires that investment companies adopt comprehensive compliance programs including, among other things, written policies and procedures reasonably designed to prevent a violation of federal securities laws and designation of a chief compliance officer (CCO). A CCO's primary responsibilities are to administer the policies and procedures and to report annually to the fund board regarding the adequacy of the compliance program. Funds must review at least annually the adequacy of their and their service providers' policies and procedures as well as the effectiveness of their implementation.
Rule 38a-1 does not prescribe how funds should conduct compliance reviews or who should conduct them. As a result, funds have ample flexibility to design and carry out compliance reviews in a manner that best suits their particular circumstances. The level of a CCO's direct involvement in the review of compliance policies and procedures will likely vary from fund complex to fund complex and may vary from year to year.
This session will focus on the regulatory framework governing the annual review and report requirements, the process for planning annual reviews and the CCO's role and issues to consider.
- Identify the principal options available in conducting reviews, including interviews, observations, data testing, trend analysis, and reports.
- Consider factors that are helpful in assessing the information contained in service providers’ reports.
- Understand best practices for conducting in-person due diligence visits to the fund’s service providers.
- Examine the process for preparing and presenting annual reports to fund boards and related recordkeeping requirements.
- Be conversant with the types of tests and reports to use in conducting fund compliance reviews.
For Whom: Designed to increase the professional competency of investment company compliance professionals with legal, compliance and management responsibilities
Suggested Skill Level: Intermediate
Instructional Method: Group Internet-Based
Advance Preparation: None
Pre-requisites for participation: The pre-requisite for participation is a basic understanding of definitions and concepts arising under the Investment Company Act of 1940 and related SEC Rules.
Continuing Education Credits:
See NRS Continuing Education Guide
Recommended CPE Credit: 2
Recommended IACCP Credit: 2
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