Write the Best Annual Compliance Program Review EVER!

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:

  1. Background
  2. Overview of the review process
  3. Identify the Principal Risks addressed through Compliance Policies and Procedures
  4. Business, Industry and Regulatory Developments
  5. Evaluation of the Adequacy and Effectiveness of Compliance Policies and Procedures, and Recommendations

Read her full post here


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