The Case for an Interim Evaluation of your Compliance Program

How prepared was your firm for the disruption of COVID-19 pandemic? Did your firm’s business continuity plan cover a pandemic? Have you adapted your compliance program since March?

The COVID-19 pandemic has forced many to rethink best practices in the face of adapting to the “new normal.” Whether your firm is continuing to work from remote locations or is beginning to get back to the office, the disruptions of the past few months require an “other-than-annual” or interim evaluation of your firm’s compliance program, particularly with respect to high risk areas. Consider:

  • What worked as intended?
  • What exceptions were made to policies or procedures?
  • Has the required documentation been maintained?

These are just some of the questions that compliance officers need to ask and, more importantly, answer.

There are many reasons for conducting an interim review of aspects of a firm’s compliance program. One is our short-term memory. While we all think that we will remember why an exception was made or how a situation was resolved, we generally will not without benefit of good documentation.  Mitigate your own risk and download CSS’s BCP checklist.

Additionally, as our experiences post-2008 demonstrated, regulators will question what challenges the firm faced during these turbulent times and how they were addressed. They will also expect that policies and controls were followed and exceptions were documented.

Compliance officers are central to documenting how a firm responded to these business disruptions and recommending what enhancements or changes should be made to a firm’s compliance program.

To read the full chapter on assessing your compliance program, download The CCO’s Playbook.


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