Many chief compliance officers struggle every year with preparing the annual review and, based on the OCIE’s summary of the most frequently identified exam deficiencies; some are not up to the task. To help you out, Jaqueline Hummel and Hardin Compliance Consulting LLC suggest the following:
The review should answer these questions:
- Were recommendations from the prior year’s annual review implemented?
- Were the firm’s compliance policies and procedures adequate and followed consistently?
- Are there any operational or compliance risks or weaknesses that need to be addressed?
- Should any changes be made to the firm’s policies and procedures?
Here’s a basic outline for the report:
- Overview of the review process
- Identify the Principal Risks addressed through Compliance Policies and Procedures
- Business, Industry and Regulatory Developments
- Evaluation of the Adequacy and Effectiveness of Compliance Policies and Procedures, and Recommendations