How Do Your Policies & Procedures Measure Up?
The SEC adopted Rule 206(4)-7 in 2004 under the Advisers Act which required each investment adviser registered with the Commission to adopt and implement written policies and procedures reasonably designed to prevent violation of the federal securities laws, review those policies and procedures annually for their adequacy and the effectiveness of their implementation, and designate a chief compliance officer to be responsible for administering the policies and procedures. How has your manual evolved in those 10 years since the rule was effected?
- Discussion of recent policies adopted (e.g., ITPP)
- Building an “effective compliance manual”
- Policies beyond the scope of the Advisers Act (FCPA, DOL related, etc.)
- Evolution of the CCO position
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