Plain-English Translation Of SEC Official's Speech To RIA CCOs Hot

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On October 15, Andrew J. "Buddy" Donohue, Chief of Staff at the U.S. Securities and Exchange Commission, put chief compliance officers at Registered Investment Advisers on notice.

"If I were a chief compliance officer," said Donohue, a regulator and financial industry executive for nearly 40 years, "I would consider my role in terms of the following categories."

According to the SEC transcript of his speech, Donohue ticked off this list:

     • Laws, Regulations and other Requirements
     • Organization and Operations of the Firm
     • Conflicts of Interest
     • Clients of the Firm
     • Compliance and Other Systems
     • Policies and Procedures
     • Markets and Business Practices
     • Culture of the Firm
     • What DON'T I know?
Donohue's speech was vague about exactly what a CCO is to do. SEC officials rarely are specific about how to comply with the law. They think it's better to be vague, so as not to encourage shortcuts by advisors..
Donohue's nine ways for CCOs to view their roles is classic SEC-regulator gobbledeygook, reminiscent of former Fed chairman Alan Greenspan's often convoluted public pronouncements on the economy.       
Fortunately, at this webinar, compliance professionals, Chris Winn and Conor Anderson, of AdvisorAssist, translate Donohue's nine categories into a list of 10 actionable items for CCOs:
  1. Regulatory requirements
  2. Firm organization and operations
  3. Identifying potential conflicts of interest
  4. Knowing the firm's clients
  5. IT compliance and firm-wide systems
  6. Firm policies and procedures, not boilerplate
  7. Forensic testing to "prove" systems work
  8. Market and business practice awareness
  9. Culture of the firm
  10. When you're a "Jack of all trades"

A4A members ($60/year) the full webinar here.

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