Nancy M. Persechino of Bingham McCutchen LLP put together her take on the Compliance Reviews of an Extraordinary Year. She also includes a chart of the changes in law and rules, new guidance, and enforcement actions (.pdf).
Given the market turbulence of the past year and the rapidly changing business and regulatory environments, many CCOs may wish to do more than simply dust off last year’s review and update its contents. At least one thing remains the same: the purpose of the annual review is to assess the adequacy of the firm’s policies and procedures in ensuring compliance with securities laws and the effectiveness of their implementation. Nothing tests the adequacy of policies and procedures quite like a crisis. So, why not treat the extraordinary events of the last year as a great “forensic test” and ask, “What went right? What didn’t?”