Advisers Act: Anti-Fraud Rules Compliance Programs Rules and Mastering the Annual Review
Description: Understanding the intricacies and implications of the Investment Advisers Act of 1940 (Advisers Act) is fundamental to the core responsibilities of any investment adviser compliance professional. A section-by-section review of the Advisers Act brings renewed focus to the root source of each requirement, many of which are likely to be encountered in compliance departments of every size firm. Everyday situations are incorporated to bring the Advisers Act to life, including practical advice about writing, implementing and maintaining policies to create strong internal controls that work within your firm’s business operations.
Anti -Fraud Rules Compliance Programs Rules and Mastering the Annual Review course highlights include:
- Rule 206(4)-7 Compliance procedures and practices
Compliance professionals must be ever mindful of the ongoing mandates embodied in Rule 206(4)-7 under the Investment Advisers Act and Rule 38-1 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”, the 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. Also being covered is 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.
For whom:
- Chief Compliance Officers
- Compliance Staff at all levels
- Internal auditors
- Legal counsel
- Management
Suggested Skill Level: Basic to Intermediate
Pre-requisites for participation: No prerequisites are required. However, attendees can benefit by reviewing the Investment Advisers Act of 1940 and the Investment Company Act of 1940 to become familiar with the structure and terms.
Each Advisers Act course provides the instruction and tools to:
- Demonstrate a clear understanding of the structure, content and terms of the Advisers Act for quick, easy reference and response
- Prioritize work flow and assign tasks for establishing effective policy, procedures and internal controls and for minimizing risk and fines
- Pinpoint the SEC areas of concern that should drive required written compliance policies and procedures
- Understand the relationship among internal controls, internal reviews and the risk-based SEC examination program
- Examine the use of checklists, timetables, SEC Document Requests Lists, exception reports and staff interviews to implement a strong compliance program
- Discuss transactional, periodic and forensic testing of policies and procedures as tools of the risk assessment process
- Identify systemic problems to initiate and implement prompt corrective action
- Understand changes in the SEC examination process
