Developing a Tailored IA Compliance Testing Program: Forensic Focus
September 14, 2010
1:00 PM – 3:00 PM EDT
Presented by: Mederic Daigneault, Senior Consultant/Director of Hedge Fund Services, NRS
Richard Seepersaud, Compliance Officer, TIAA-CREF
Description: In its release adopting Rule 206(4)-7 under the Investment Advisers Act of 1940, the SEC stated that an investment adviser’s policies and procedures should employ “compliance tests that analyze information over time” to determine the effectiveness of its compliance policies and procedures. SEC examiners expect that advisers, to the extent applicable, will develop a test plan that combines three compliance tests: Transactional, Periodic and Forensic. The SEC staff has repeatedly sent clear signals in CCOutreach Seminars, speeches and elsewhere that they are taking the issue of forensic testing seriously. SEC Document Request Lists typically request information relating to the firm’s compliance surveillance, and/or forensic or transactional testing.
This presentation will provide an understanding of the forensic testing process. The session will also impart guidance on how to develop, implement and document an effective compliance testing plan that tracks your firm’s risk assessment and that will support your annual review.
For Whom: Compliance Officers, legal counsel, internal auditors, managers and any person who has day-to-day interaction with compliance.
Suggested Skill Level: Basic to Intermediate
Instructional Method: Group - Internet Based
Pre-requisites for participation: No prerequisites are required. However, attendees can benefit by reviewing the Investment Advisers Act of 1940 to become familiar with the structure and terms.
Continuing Education Credits: Recommended CPE Credit: 2
Recommended IACCP Credit: 2
