Your investment adviser’s chief compliance officer (“CCO”) must be knowledgeable regarding the Investment Advisers Act of 1940, competent in regard to administering your compliance program and empowered to enforce compliance with your policies and procedures.
Your investment adviser’s CCO is responsible for administering your investment advisers’ policies and procedures. This does not necessarily mean that the CCO has to be the sole party responsible for performing all the investment adviser’s supervisory functions. In order to properly delegate some of the supervisory functions, an investment adviser’s CCO must: (i) adopt procedures that are reasonably designed to prevent and detect violations of the federal securities laws; (ii) ensure that a system is in place for applying the procedures; and (iii) make sure that all supervisory responsibilities are reasonably discharged in accordance with the investment adviser’s written policies and procedures in such a manner that the investment adviser’s CCO has no reason to believe that the supervised persons are not complying with the procedures. It is the ultimate duty of the CCO to develop, implement, maintain, and enforce your investment adviser’s written compliance policies and procedures. The CCO does not need to be responsible for all policies and procedures of your investment adviser firm; however, your firm’s CCO needs to understand Rule 206(4)-7 well enough to know what his/her responsibilities are under the rule.
“Rule 206(4)-7 requires each adviser registered with the Commission to designate a chief compliance officer to administer its compliance policies and procedures. An adviser’s chief compliance officer should be competent and knowledgeable regarding the Advisers Act and should be empowered with full responsibility and authority to develop and enforce appropriate policies and procedures for the firm. Thus, the compliance officer should have a position of sufficient seniority and authority within the organization to compel others to adhere to the compliance policies and procedures.”
-Securities and Exchange Commission (full text here)
RIA Compliance Consultants is hosting a webinar, “Basic Training for a CCO,” on Thursday, August 18, 2011. This webinar will provide valuable information and tips regarding ongoing responsibilities for your investment adviser’s chief compliance officer in order to avoid violating SEC Rule 206(4)-7.
RIA Compliance Consultants is a team of industry experienced professionals dedicated to working with investment advisers who are also committed to implementing good compliance and risk management strategies. By working together, RIA Compliance Consultants helps investment advisers navigate the maze of investment adviser compliance regulations and find the best ways to satisfy their obligations.
Webinar: Basic Training for a CCO
Date: Thursday, August 18, 2011
Time: 12:00 p.m. to 1:00 p.m. Central
To register, click here.