In Season 6 Episode 1 of The Securities Compliance Podcast: Compliance in Context, host and Calfee Partner Patrick D. Hayes takes an in-depth look at maximizing your compliance resources, doing less with more, and getting the most out of what's available to effectively run your firm's compliance program to the best of your ability. Louis Dempsey and Bart McDonald from Renaissance Regulatory Services help guide the conversation. In the Headlines section, Patrick reviews some recent rule withdrawals and leadership changes at the SEC. The episode closes with another installment of Outtakes, where a recent enforcement action reminds us of the importance of having proper disclosures for fees and conflicts of interest.
Show
Headlines
- SEC Withdraws 14 Rulemaking Proposals
- SEC Chair Atkins Fills Key Leadership Roles
Interview with Louis Dempsey and Bart McDonald
- Background on maximizing your compliance resources
- Discussing best practices to operate on a limited budget
- Evaluating the impact of new regulations, including the FinCEN AML Rule and Regulation S-P
- Analyzing compliance efficiencies in Code of Ethics, electronic communications, conflicts of interest, registration and licensing, compliance testing, and documentation of completed tasks
- Reviewing the significance of a strong training program.
- How does your firm's registration type impact how you can best maximize compliance resources?
Outtakes
- Recent enforcement action reminds us of the importance of having proper disclosures for fees and conflicts of interest.
Quotes
08:48 – "Really, the risk assessments are incredibly important to help you focus where you want to put your energy and put your time and we'll get into some of that later. From a bigger picture standpoint, you want to leverage your custodians, your custodial relationship. They all have tools that they provide and can help from a compliance perspective, whether those are exception reports, trade reports—and don't forget you also most of them have discounts for other vendors—so whether it's proxy services or really a whole host of items, you want to become familiar with that, you want to stay on top of the reporting capabilities, and...you also have the NSCP. So you really want to look at joining compliance roundtables or other peer networks—that really helps from a practical standpoint." – Bart McDonald
13:06 – "Think of compliance as a journey, as a road trip. You've got a certain amount of things that you need to get done and you've got 365 days to get them done in. Create a map, create a checklist, create a calendar on what you're going to do and when you're going to do it. Don't wait till the end of the year to do all your testing. Do things throughout the course of the year. If you're a big picture person, no matter how much you know the rules, no matter how much you know the laws, no matter how long you've been in the industry, you still have to have that. And if you're not a detailed organized person and you have the resources, hire somebody that is, that can be that navigator for your compliance program." – Louis Dempsey
34:24 – "Your weakest link is probably your reps. So, you really, especially from a customer information standpoint, so you really want to put some good training together. And, you know, I know that can be "here, do this, you know, this webinar" or "do this little read this," but you really want to, you know, get in front of them. And, you know, like with anything—like with my kids—you got to say it three times before they hear it. So you really want to push that training." – Bart McDonald
About the Securities Compliance Podcast: Compliance in Context
Introducing the Securities Compliance Podcast: Compliance in Context presented by Calfee, Halter & Griswold, and the National Society of Compliance Professionals and hosted by Patrick D. Hayes, Partner and Chair of Calfee's Investment Management practice.
Designed as a personal master class for the securities legal and compliance professional, this podcast embodies Patrick's passion to help you put Compliance In Context" by combining the technical expertise of industry thought leaders and innovators with the practical experience of doers and key decision makers.
Listeners will find the podcast on Apple Podcast, Google Podcast, and Spotify.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
