Early and Often: Compliance Training Pays Big Dividends for Private Fund Advisers

Rule 206(4)-7 under the Investment Advisers Act of 1940 requires advisers to adopt policies and procedures “reasonably designed” to prevent violations of the Act.  This responsibility includes a mandate that the Chief Compliance Officer identify potential and actual conflicts of interest and compliance risks and then address them.  Training will be central to the response by private fund advisers to significant compliance breaches, changes in business arrangements and regulatory developments.  Just as importantly, employees of private fund advisers will be far better equipped to avoid violations of the Act if they understand it.  In a guest article, Philip Thomas, an investment management attorney at Garrity, Graham, Murphy, Garofalo and Flinn, P.C., offers ideas on how to build a training program that works for private fund advisers.

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