Damage Control: What to do When Your Firm Breaks the Rules
Course Description: Even the most diligent firms with strong and effective Compliance and Risk Management processes in place can find themselves facing major problems. When risk events inevitably occur, will you know how to respond? The importance of successfully managing and containing these situations cannot be overstated.
A crisis can hit in many forms:
- Two FBI agents arrive unexpectedly and ask to speak to the company controller.
- Your VP of Investor Relations gets an ominous telephone call from the SEC's Enforcement Division. Simultaneously, a "Document Preservation" notice from the SEC is delivered to your office.
- A news reporter calls with a few questions about certain payments made by a company sales representative to a foreign government official.
- You learn that a current employee has become a "whistleblower" and has provided confidential information and documents to government agents.
- You start getting panicked phone calls and emails from top management, seeking your guidance.
This session will provide guidance about what to do and, of equal importance, what not to do, at the onset of the crisis.
Our expert panelists will also outline the red flags of a systemic problem and immediate steps to take and the pitfalls to avoid. They will sort out the approaches that are appropriate to different situations that include:
- trade errors
- breaches of client investment guidelines
- rogue employees
- information breaches
- misrepresentations as to the value of assets or performance
- failure to disclose conflicts of interest such as such as soft dollar arrangements and regulatory violations
After attending this course, attendees should be able to:
- Draft a damage control plan
- Respond to risk events in a manner that limits damage to the firm and clients, and minimizes reputational risk
- Take appropriate steps to manage crisis mitigation, notification and escalation, employment of counsel and/or outside reviewers, legal privileges, dealing with aggrieved clients and other critical decisions
- Control issues relating to self–reporting to regulators, private litigation and enforcement proceedings
- Handle press inquiries
For Whom: Chief Compliance Officers, Internal auditors, Compliance Staff at all levels, Marketing personnel, Legal counsel, Management
Suggested Skill Level: Intermediate
Instructional Method: Group-Internet-Based
Pre-requisites for participation: No prerequisites are required.
Continuing Education Credits:
See NRS Continuing Education Guide
Recommended CPE Credit: 2 in the Regulatory Ethics field of study