A straightforward discussion of compliance program requirements

Abstract

The challenges involved in meeting the new requirements of Rule 206 (4)‐7 under the Investment Advisers Act of 1940 and Rule 38a‐1 under the Investment Company Act of 1940 will be substantial for some organizations. At a minimum, all organizations will be required to document their compliance policies and procedures. Also, many firms, particularly fund managers and advisers with large or complex operations, most likely will be required to institute a number of additional control processes as a result of the new rules. Additionally, many organizations probably will need to reevaluate their compliance resource needs in order to successfully implement the new rules by their compliance date. Among the issues this article highlights are coverage of compliance programs in SEC examinations; development of functional policies, procedures, and controls; compliance staffing needs; and oversight by funds’ boards of directors.

Citation

Scott, D.E. (2004), "A straightforward discussion of compliance program requirements", Journal of Investment Compliance, Vol. 4 No. 4, pp. 20-26. https://doi.org/10.1108/15285810310813248