Regulators have been emphasizing the need for investment advisors to develop and maintain a culture of compliance. Of course, one of the best ways to implement a culture of compliance is for the firm to establish adequate training and continuing education programs.
We recommend that advisor firms hold some form of compliance training or meetings on a monthly basis. These could come in the form of department meetings, on-line continuing education programs, or company-wide teleconferences or web-casts. Each session should be documented and a list kept of those in attendance or those that completed the training.
In light of the SEC’s Code of Ethics rule, a special emphasis needs be given to training employees and advisor representatives on the firm’s Code of Ethics, which would include the firm’s insider trading and personal securities transactions policies. Further topics for compliance meetings and training could cover other policies and procedures of the firm, recent regulatory changes and current compliance hot topics.
Another important requirement is to ensure all employees and advisor representatives read and acknowledge their understanding of the firm’s compliance and supervisory procedures manual(s). This should be done on at least an annual basis. In addition, any updates made throughout the year should be sent to every employee and advisory representative upon implementation.
Does your firm have a good continuing education program? Do you provide on-going compliance training? Maybe you do and just need a little guidance on what to cover next. Whatever the case may be, give us a call. We can help you identify and prioritize the issues that your advisor representatives need to know so your firm can achieve a culture of compliance.
Posted by Bryan Hill
Labels: Code of Ethics, Compliance Program