Posts By: Victoria Olson

Effective Compliance Policies & Procedures and Annual Reviews: Meeting the Reasonably Designed Standards

Sometimes it seems that enough is never really enough. While compliance officers have grown intimately familiar with SEC Rule 206(4)-7 over the past 15 years since the Rule became effective, deficiencies in connection with the Compliance Program Rule continue to rank among the most frequently cited issues identified in OCIE examinations of investment advisers. It … Continued

Refreshing the Annual Review Process to Address Business and Regulatory Risks

Rule 206(4)-7 requires each registered adviser to review its policies and procedures no less frequently than annually, to determine their adequacy and the effectiveness of their implementation. But what’s the best way to approach this review? How are other firms meeting this requirement? At the recent Ascendant Compliance Solutions Strategies 2019 Spring Conference in Miami … Continued

Compliance 2.0 – Being a Strategic Partner in Your Firm

Compliance as a profession continues to evolve. With Enron, Bernie Madoff and numerous other failures paving the way for rulemaking across industries and nations, the days of drawing a short straw, getting drafted into a compliance role and operating in isolation outside of the business are – or should be – ancient history. Since the … Continued

Big Data Part III: Preparing for the Future of Global Regulatory Governance

United States and European Union reporting requirements imposed on investment managers have exploded since the Global Financial Crisis and, with the imminent arrival of SFTR in Europe, it seems poised to expand again. The challenge of reporting trades, transactions and contracts in multiple jurisdictions requires firms to embrace technology as regulators continue to look to … Continued

Mailing List