Overview
Course Description:
Compliance professionals must be ever mindful of the ongoing mandates embodied in Rule 206(4)-7 under the Investment Advisers Act and Rule 38a-1 under the Investment Company Act to maintain, review, test and modify written compliance policies and procedures that are reasonably designed to detect violations and weaknesses in internal controls and compliance systems. Commonly referred to as the “Compliance Programs Rules,” these rules specifically require that advisers and funds implement and maintain policies and procedures designed to detect, prevent and correct compliance problems in key areas of their operations and to conduct an at least annual review to gauge their effectiveness.
This seminar will identify essential internal controls and compliance testing and documentation procedures within the structure of a “real-world” practical compliance program. The seminar will also deal with how to conduct periodic or annual compliance reviews that identify and address compliance gaps or risks, including the level of detail appropriate for an annual review report.