Tailoring a fund manager’s compliance program is not a one-and-done project. The program needs to be regularly reviewed and, if necessary, updated. Those reviews can be triggered by internal events, such as breaches of fund policies or material changes to the fund’s operations, or external events, such as the adoption of new rules by the SEC. This three-part series explores the logistics of tailoring a fund manager’s compliance program. This third article identifies five key triggers for a review – and possible update – of a fund manager’s compliance program. The first article outlined the expectations of the SEC, DOJ and investors as to the customization of compliance programs, as well as the consequences of failing to tailor the program. The second article laid out what fund managers should consider when tailoring their programs, including the role of off-the-shelf programs. See “Challenges and Solutions in Managing Global Compliance Programs” (Oct. 5, 2017).