Skip to content

Compliance Building

Doug Cornelius on compliance for private equity real estate

Menu
  • Home
  • About
    • About
    • About Doug
    • About This Website
    • Why I Blog
    • Speaking Engagements
    • Contact
    • Publications
  • Archives
    • Topic Archive
    • Book Reviews
    • Most Popular
  • Subscribe
  • Disclaimers
    • Disclaimers
    • Policies and Procedures
    • Use of Site Content
    • Comments
    • FTC Disclosure
Menu

IDC Task Force Report Identifies Key Characteristics for Strong Compliance Programs

Posted on September 22, 2009September 17, 2009 by Doug Cornelius
Print Friendly, PDF & Email

IDC

Independent Directors Council published a new task force report on the characteristics of a strong mutual fund compliance program. These include an ethical, compliance-focused “tone at the top;” a collaborative approach by the fund’s chief compliance officer; a risk-based program tailored to the fund and the adviser’s business; transparency and candor among the CCO, fund board, and adviser; and knowledgeable staff armed with appropriate resources.

The adoption of the fund compliance program rule (Rule 38a-1 under the Investment Company Act of 1940) in 2003 presented mutual fund boards with the required addition of a chief compliance officer to administer the fund’s compliance program.

The report does not break any new ground or propose radical changes. But it does provide some resources to think about and evaluate compliance.

One of interesting structural issues with mutual funds is whether the CCO should serve as the fund’s and adviser’s CCO or only as the fund CCO. By separating the role, you remove potential conflicts. Plus, the fund CCO could serve as a useful complement or counterpoint to the adviser’s CCO. But the fund-only CCO may feel like an outsider and a threat since most of the employees will be working for the adviser.

Share this:

  • Print (Opens in new window) Print
  • Share on Facebook (Opens in new window) Facebook
  • Share on LinkedIn (Opens in new window) LinkedIn
  • Share on X (Opens in new window) X
  • Email a link to a friend (Opens in new window) Email

Leave a ReplyCancel reply

This site uses Akismet to reduce spam. Learn how your comment data is processed.

Search for Stuff

Recent Stories

  • PERE 100 and SEC Registration
  • Neither Admit Nor Deny To Be No Longer
  • What Will Form PF Look Like Next Year?
  • Is It a Chipset or Is It a Security?
  • When the Lawyer Is Breaking Bad
  • Will Investors Have an Appetite for Semi-Annual Reporting?
  • Special Forces Trading on Insider Knowledge
  • Prediction Markets and Compliance Programs
  • The One with the Line That Goes Straight Up and Right
  • The One with the Crypto Paying for a Mega-Shilling Package

Fight Cancer

Please support my Pan-Mass Challenge
Make a donation to fight cancer. donate.pmc.org/DC0176
pan-mass challenge badge

I am a lawyer, but I am not your lawyer. Since I’m a lawyer, this website may be considered attorney advertising under the ethical rules of certain jurisdictions. Please read my disclaimers page before taking any action. And then, don't take any action based on what I wrote.

Creative Commons logo with the text 'Some Rights Reserved' and three symbols representing attribution, non-commercial use, and share alike.

Compliance Building - by Doug Cornelius is licensed under a Creative Commons Attribution-Noncommercial 3.0 United States License.