RCA Symposium Explores Common Examination Risk Areas (Part One of Two)

At the Compliance, Risk & Enforcement Symposium sponsored by the Regulatory Compliance Association (RCA), a panel of chief compliance officers (CCOs) and regulatory attorneys discussed the current regulatory environment that private fund advisers are facing. The program was moderated by Robert Van Grover, partner at Seward & Kissel, and featured Lawrence S. Block, managing director, counsel and CCO of Island Capital Group; David L. Fitzgerald, general counsel and CCO at Gabelli & Company; Lucy Frew, partner at Walkers; Michael C. Neus, general counsel of ExodusPoint Capital Management; Heather Traeger, CCO of the Teacher Retirement System of Texas; and Steven A. Yadegari, chief operating officer and general counsel at Cramer Rosenthal McGlynn. This article, the first in a two-part series, covers compliance issues that are likely to come under SEC scrutiny during an examination, including an adviser’s culture of compliance; marketing and other disclosures; addressing past compliance deficiencies; compliance training; and cybersecurity. The second article will discuss challenges associated with fee and expense allocations; social media; and political contributions, as well as the current regulatory climate in the Cayman Islands. For additional coverage of events sponsored by the RCA, see “Compensation Trends Panel Discusses Strong Market for Private Fund Compliance and Legal Personnel” (Jan. 25, 2018); “SEC, NFA and OFAC Shed Light on Their AML Enforcement Efforts and Priorities” (May 4, 2017); and “Usable Lessons and Proven Survival Techniques From the Hedge Fund Examination Trenches” (Oct. 24, 2014).

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