Recent Security and Exchange Commission (“SEC”) examinations of investment advisers have again focused on the knowledge and authority of the Chief Compliance Officer (“CCO”). Rule 206(4)-7 requires investment adviser firms to designate a supervised person as CCO. In addition, the SEC states in Release No. 2204, that in order for the supervised person to compel others to adhere to the compliance policies and procedures they must be in “a position of sufficient seniority and authority within the organization.” For many firms, the CCO has other managerial responsibilities and, therefore, is challenged to stay informed on the ever changing regulatory environment. The CCO continues to require support to implement effective policies and procedures that adequately monitor the firm’s policies and procedures.
Some resources to help the CCO, compliance staff and firm employees identify and manage risks and determine appropriate compliance controls may be found below.
- Subscribe and read the Warner Norcross & Judd LLP Compliance Corner Blog http://compliancecorner.wnj.com/
- Bookmark and periodically visit the SEC’s website http://www.sec.gov/divisions/investment.shtml
- Review Staff Guidance and Studies
- Review recent No-Action and Interpretive Letters
- Join the National Society of Compliance Professionals (“NSCP”) a non-profit organization that provides support to compliance professionals in the securities industry. Membership benefits include:
- Access to webinars, regional and national conventions
- Subscription to NSCP Currents, a bi-monthly compliance journal
- Additional information may be found at http://www.nscp.org/.
- Attend the NSCP’s National Conference October 22 – 24, 2012 in WashingtonD.C. https://www.eiseverywhere.com/ehome/42305
- Conference will cover over 80 topics for compliance professionals at IA, BD, Hedge Fund/Private Fund and Investment Companies.
- Workshops applicable to small and large firms
- CCOs and other compliance professionals will benefit from relevant information.
Contact any member of the Broker Dealer/Investment Adviser Practice Group at Warner Norcross & Judd to see how we might assist you with your compliance matters.