Working in the financial regulatory compliance landscape can be…challenging. And as the person in charge of creating your corporate compliance program AND complying with the letter of the law when it comes to rules set out by entities like the Securities and Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA), we know the sheer act of simply “keeping up” can be a daunting one.
As the chief compliance officer or professional serving your organization, you have quite a few tasks on your overarching to-do list. And one of the biggest one? Aligning your corporate compliance program with the financial regulatory compliance landscape to ensure your entire organization – be it a hedge fund, private equity firm, registered investment adviser or public company – is working in tandem to help you mitigate risk and remain in compliance.
Creating a culture of compliance at your financial firm – What is corporate compliance?
There are few definitions of corporate compliance out there, but in its simplest form, it is the policies and procedures set forth by internal bodies. In other words, the SEC and FINRA don’t have any say in your corporate compliance. However, in an effort to work smarter and not harder, financial firms would be wise to align their corporate compliance program with relevant regulatory bodies to show their firm-wide culture of compliance.
Aligning corporate compliance with the financial regulatory compliance landscape
Given the influx of new regulations and rulings coming from the SEC, it would be understandable if firms struggled to properly align their corporate compliance program with the overarching financial regulatory landscape. To help get you started on the right path, we’ve aggregated our top five pieces of advice to help you align your program and maintain compliance both on the corporate and regulatory front.
1.Stay up to date on what’s happening in the regulatory compliance landscape.
Whether it’s setting a Google alert, registering for that extra webinar or subscribing to industry publications, the more you can stay informed, the better off you’ll be.
2. Tailor policies and procedures to your firm’s unique risk points.
Policies and procedures are not a one-size-fits-all kind of deal. And regulatory bodies tend not to look kindly on those firms who simply copy and paste. By customizing your policies up front, and aligning your procedures to match, you ensure your compliance program, and the firm at large, are doing what they should to mitigate potential risk factors.
3. Educate your firm on the why behind your corporate compliance program.
Not everyone at your firm is an expert in compliance, and nor should they be. However, without that contextual understanding, it can often be difficult for firm employees to stand behind the program. Clearly stating why you have your specific policies and procedures in place and why every employee should be an active participant in your culture of compliance sets your program up for success. After all, there is no I in team.
4. Document everything.
What’s that old saying? If it isn’t documented, it didn’t happen? Thoroughly documenting your corporate compliance program and the procedures therein will most certainly come in handy when (not if) regulators come to examine your firm.
5. Continually audit your needs and the requirements placed on your firm by regulatory bodies.
What worked yesterday might not work today. And what works today may not work tomorrow. Regulatory compliance is an evolving function of the financial industry and in order to align your corporate compliance program with the landscape at large, you must be evolving your program right along with it.
While corporate compliance may be a particular focus this week (after all it is Corporate Compliance and Ethics week) it by no means falls to the wayside come next Monday morning. In aligning your corporate compliance program with the financial regulatory compliance landscape, you affirm your programs standing and more effectively mitigate the risk of non-compliance.