If you haven’t begun testing your compliance program AND documenting the tests, then it is time to begin. This is on the regulators radar screen. My plan is to give you some steps to work toward this during your “down time” this summer.
First step – Develop a Risk Assessment. Use the following as a place to start on your assessment:
- Safety of Assets
- Compliance with Pay to Play Rule (if applicable)
- Conflicts of Interest Related to Asset Allocations
- Conflicts fo Interest related to Compensation
More to follow in the weeks ahead. But this should take some time to get started. Happy assessing!!