The Office of Compliance Inspections and Examinations (or OCIE)
recently issued a Risk Alert that identified the five most frequent
compliance topics that arising from OCIE examinations. These
compliance topics include the following:
- Deficient compliance programs,
- Late or insufficient filings,
- Violations of the custody rule,
- Code of Ethics compliance
deficiencies, and
- Books and records.
Among other things, OCIE noted that it continues to see
untailored "off-the-shelf" manuals, deficient or
non-existent annual reviews, as well as the systemic failure to
follow procedures. So what does this all mean?
It would certainly appear from OCIE's analysis that firms
continue to take the easy way out when it comes to compliance.
There is nothing per se wrong with an
"off-the-shelf" compliance manual. The impropriety comes
when the firm does nothing to modify that manual to conform to its
business model. Not conforming a compliance manual to your
individual
