The Regulatory Compliance Association (RCA) recently held its Enforcement, Compliance & Operations (ECO) 2014 Symposium in New York City. The Symposium addressed numerous relevant issues, including how a hedge fund manager should develop a supervision and remediation process that complies with Rule 206(4)-7 under the Investment Advisers Act of 1940. The rule requires registered investment advisers to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act; review at least annually the adequacy of those policies and procedures and the effectiveness of their implementation; and designate a person responsible for administering the adopted policies and procedures. Symposium panelists explained that an effective compliance program must include four key elements. This article identifies and discusses those elements. For coverage of other topics from the ECO Symposium, see “RCA Enforcement, Compliance and Operations 2014 Symposium Offers Insight from Top SEC Officials on Custody, Conflicts, Broker Registration, Alternative Mutual Funds and the JOBS Act (Part One of Two)
,” Hedge Fund Law Report, Vol. 7, No. 22 (Jun. 6, 2014); and “RCA ECO 2014 Symposium Offers Insight from Top SEC Officials on Cybersecurity, Reg M, Examinations, Insider Trading Investigations, the Newman Appeal, Expert Networks and Political Intelligence (Part Two of Two)
, Hedge Fund Law Report, Vol. 7, No. 25 (Jun. 27, 2014). See also “Top SEC Officials Discuss Hedge Fund Compliance, Examination and Enforcement Priorities at 2014 Compliance Outreach Program National Seminar (Part Three of Three)
,” Hedge Fund Law Report, Vol. 7, No. 9 (Mar. 7, 2014).