Ever since the SEC and other regulatory bodies (i.e., FINRA) identified the possibility of “significant business disruptions” many years ago and mandated that registrants create, maintain, and test a Business Continuity Plan (“BCP”), these plans have rarely been taken very seriously until they are needed.
In this final part of our third Interview (Part 1, Part 2). Bo Howell continues his discussion with Charles Black about the DO's and DON'Ts of SEC Exams. Charles brings over 17 years of experience in the financial services industry to provide great tips and insight on what to do when the SEC calls.
Having the right policies and procedures in place is a key component of an effective compliance program but it’s only part of the equation. Maintaining consistent adherence to these policies and procedures is equally important. One of the things our customers have asked for is a more efficient and automated way to do this. That’s why we are excited to announce the official release of our Testing Manager, the fourth component in our integrated web-based compliance platform for small- and mid-sized registered investment advisers (RIAs).
In part two of our panel recap where we discussed compliance testing programs for small and medium-size firms, we zero in on the foundation. (If you missed part one: a top-down approach, you can find it here.) Flipping the top-down approach that we discussed las week, we began to look at critical components of the business and how to review and test your procedures effectively. The following are some critical areas of an adviser’s business that require testing, along with tips to keep you in the game.
PART 1 - The Top Down Approach
I had the good fortune to participate in a compliance panel with esteemed adviser CCOs in which we shared our lessons learned about building and maintaining effective compliance testing programs from top to bottom. To avoid drinking from a fire hose, I will cover the nitty-gritty details in a two-part blog, one starting from the top and the other building up from the ground floor.