Realistic assessment of whether the firm is able to implement and ensure compliance with its present program in consideration of any resource limitations and the firm's management culture.
A comprehensive "gap" analysis
Is the program transparent and comprehensible to employees?
Separation of functions
establishment of compliance committee or other deliberative body
Reasonableness and documentation of compliance monitoring and periodic testing
Compliance education and training
Clearly distinguishing which responsibilities will be delegated to the compliance unit, and which to the business side of the organization. Effective compliance programs are predicated on two assumptions: the business side is responsible for the day-to-day control activities that are designed to ensure compliance, and the compliance unit has the oversight responsibility to monitor the compliance program and determine whether it is adequately implemented and enforced.
Adoption and maintenance of clear and well-defined organizational charts that illustrate personnel, business functions and responsibilities, as well as the supervisory structure for the firm and each department or function within the firm.
After attending this course, you will be able to:
- Assess whether your firm's compliance program is adequately designed and structured and that your firm is positioned to ensure its implementation.
- Distinguish responsibilities between compliance and the business side of the firm.
- Perform a "gap" analysis to determine if your compliance program is complete and where additional work, if any, is needed to meet regulatory requirements.
For Whom: Chief Compliance Officers, Ethics Officers, Compliance Staff at all levels Management, Legal counsel, Auditors
Suggested Skill Level: Intermediate
Instructional Method: Group - Internet Based
Pre-requisites for participation: No prerequisites are required. However, attendees can benefit by reviewing the Investment Advisers Act of 1940, especially Rule 206(4)-7, to become familiar with the structure and terms.