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Compliance Programs Rules and Strategies for Managing Your Annual Review
Compliance professionals must be ever mindful of the ongoing mandates embodied in Rule 206(4)-7 under the Investment Advisers Act and Rule 38a-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,” these 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 an at least annual review to gauge their effectiveness.
This session will identify essential internal controls and compliance testing and documentation procedures within the structure of a “real-world” practical compliance program. The session 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.
After attending this session, attendees should be able to:
- Demonstrate a clear understanding of the structure, content and terms of the Advisers Act for quick, easy reference and response
- Use the framework of the Advisers Act to prioritize work flow and assign tasks for establishing effective policy, procedures and internal controls, and for minimizing risk and fines
- Pinpoint the SEC areas of concern that should drive required written compliance policies and procedures
- Analyze the relationship among internal controls, internal reviews and the risk-based SEC examination program to better determine your firm’s compliance risk and to take actions to minimize your firm’s exposure to more frequent examinations, enforcement investigation, and fines
- Examine the use of checklists, timetables, SEC Document Requests Lists, exception reports and staff interviews to implement a strong compliance program
- Use transactional, periodic and forensic testing of policies and procedures as tools of the risk assessment process
- Identify systemic problems to initiate and implement prompt corrective action
- Adopt changes in the SEC examination process to help ensure a successful examination outcome
- Monitor regulatory changes as they occur
For whom: Designed to increase the professional competence of investment adviser professionals with legal, compliance and management responsibilities.
Suggested Skill Level: Intermediate
Instructional Method: Group Internet-Based and Group Live
Pre-requisites for participation: No prerequisites are required. However, attendees can benefit by reviewing the Investment Advisers Act of 1940 and the Investment Company Act of 1940, especially Advisers Act Rule 206(4)-7 and Investment Company Act Rule 38a-1, to become familiar with the structures and terms.
Advance Preparation: None