Rule 206(4)-7 requires each investment adviser registered (or required to be registered) with the Securities and Exchange Commission (SEC) to: (i) adopt and implement written policies and procedures reasonably designed to prevent violation of the Advisers Act and related rules (ii) review, no less frequently than annually, the adequacy of the policies and procedures and the effectiveness of their implementation; and (iii) designate a Chief Compliance Officer (CCO) responsible for administering those policies and procedures. As such, every CCO must consider, on an annual basis (and, in many cases, on an ongoing basis), how to best discharge this review obligation.
This seminar, which is being hosted by the Regulatory Compliance Association, will allow listeners the opportunity to learn the following:
- How to summarize the Rule’s Annual Review Requirement;
- How to examine the Staff’s expectations for Annual Reviews;
- How to discuss and apply industry best practices;
- How to discover how to plan and conduct a review in different organizations;
- How to identify recordkeeping and documentation requirements;
- How to discuss how to address potential compliance issues that may be identified; and
- How to consider recent SEC areas of focus that must be considered.
Dechert partner Michael Sherman will serve as the senior fellow from practice during this seminar. Also, Dechert partner Richard Horowitz will serve as a guest lecturer.
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