Mike Dryton
Description:
Compliance professionals must be ever mindful of the ongoing mandates embodied in Rule 206(4)-7 under the Investment Advisers Act and Rule 38-1 under the Investment Company Act to maintain, review, test and modify written compliance policies and procedures that are reasonably designed to detect violations and weaknesses in internal controls and compliance systems. Commonly referred to as the Compliance Programs Rules, the rules specifically require that advisers and funds implement and maintain policies and procedures designed to detect, prevent and correct compliance problems in key areas of their operations and to conduct, at least, an annual review to gauge their effectiveness. This seminar will identify essential internal controls and compliance testing and documentation procedures within the structure of a "real-world" practical compliance program. The seminar will also deal with how to conduct periodic or annual compliance reviews that identify and address compliance gaps or risks, including the level of detail appropriate for an annual review report.
For whom:
Chief Compliance Officers and others working in the compliance area, internal auditors, legal counsel and managers.
Learning Objectives:
Learn about the use of exception reports, staff interviews, SEC Document Request Lists and compliance checklists.
Discuss transactional and forensic testing of policies and procedures as tools of the assessment process.
Identify systemic problems that require prompt corrective action.
Learn to ensure that corrective action has been implemented.
Be trained to conduct and document compliance reviews and corrective actions.
Gain insights into how annual reviews are being evaluated by SEC examiners.
Pre-requisites for participation:
No prerequisites are required. However, attendees can benefit by reviewing SEC Regulation S-P.