Do you need a certification to be compliance professional? “Need” is not the right answer. Compliance is still a diverse and complex field, where the needs can differ remarkably from firm to firm. I’m a bit skeptical that a generic certificate program is likely to help me much with my job or professional development. Whatever … Read more »
Tag: SEC Release No. IA-2204
Job Description For CCOs of Advisers to Private Investment Funds
Back in 2005, Associate Director Office of Compliance Inspection and Examinations of the SEC, Gene Gohlke gave a speech addressing hedge funds who would soon have to register under the doomed hedge fund rule. He focused on what the funds needed in a Chief Compliance Officer. Rule 206(4)-7 requires a registered investment adviser to designate … Read more »
Disciplinary Actions Against Chief Compliance Officers
The Chief Compliance Officer should be a model for employee conduct. I don’t thing there is any better way to lead and educate than to set an example. Not all Chief Compliance Officers succeed in this role and some get subject to discipline. Here are some ways to get in trouble. Participation in Wrongful Conduct … Read more »
Investment Advisers and Business Continuity Plans
When an investment adviser is designing its policies and procedures you need to identify the risks for their firm so they address those risks. A big risk is missing an applicable requirement under the regulatory scheme. So you sit down with the regulations and tie them to your specific policies and procedures. An easy one … Read more »