Looking to update your compliance program in 2019? 

If so, you’ll want to review these eleven key takeaways from Jaqueline Hummel at Hardin Compliance Consulting LLC.

1. Be ready for the SEC’s scrutiny of conflicts of interest.

2. Confirm your compliance program addresses the most frequent advisory fee and expense compliance issues identified in examinations of investment advisers identified in the SEC’s risk alert

3. Review OCIE’s risk alert: most frequent best execution issues cited in adviser exams and confirm your policies, procedures and practices address the deficiencies cited.

4. Review the risk alert: investment adviser compliance issues related to the cash solicitation rule and make sure your firm has a process in place to comply with the requirements of rule 206(4)-3.

5. Address how electronic messaging is being used for business communications and confirm whether your firm is retaining the required records.

6. Be prepared for examiners continued scrutiny of custody issues.

7. Watch your back.

8. Adopt policies and procedures to protect senior and vulnerable investors.

9. Shore up your cybersecurity policies and procedures.

10. Mutual fund and ETF advisers, and their sub-advisers, should review the risk alert: risk-based examination initiatives focused on registered investment companies and prepare to be examined.

11. Advisers to mutual funds and ETFs should be working on their liquidity risk management programs to comply with investment company act rule 22e-4.


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