Managing Conflicts and Developing Effective Compliance Policies and Procedures

Rule 206(4)‑7 under the Investment Advisers Act of 1940, known as the Compliance Rule, establishes the fundamental parameters for an investment adviser’s regulatory compliance program, including adopting appropriate policies and procedures; conducting an annual compliance review; and appointing a qualified CCO. A recent installment of ACA Group’s “Building a Gold Standard Compliance Program” series focused on identification and mitigation of conflicts of interest; minimum compliance program requirements; compliance manuals; compliance policies and procedures; desk procedures; and recent SEC compliance-related examination and enforcement activity. The program featured Jaqueline Hummel, director of thought leadership, and Myles Blechner, director – investment advisory consulting, at ACA Group. This article synthesizes their insights. See our three-part series on tailoring a compliance program: “Why Fund Managers Should Customize” (Jul. 16, 2020); “What Fund Managers Should Consider” (Jul. 23, 2020); and “When Fund Managers Should Review and Update” (Jul. 30, 2020).

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