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The 7 Attributes of an Effective Compliance Officer

posted in: Thoughts | 0

While we could probably list dozens of attributes that an effective chief compliance officer SHOULD have, we have come up with 7 that they MUST have. An informal survey of CCOs revealed that the very the first attribute – a keen understanding of the regulatory landscape – has consistently been the most difficult to master.

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Analysis of the Regulatory Landscape

posted in: Regulatory | 0

One of the most daunting aspects of being a marketplace lender is determining what laws and regulations are applicable to your business. After all, if you don’t come under the authority of a specific regulator (think broker-dealers and FINRA or investment advisers and the SEC), then you might end up being subject to numerous regulatory regimes and at the mercy of multiple regulatory authorities.

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6 Steps to Building an Effective Compliance Program

posted in: Thoughts | 0

Building an effective compliance program goes beyond having a compliance manual or code of ethics, although these are obviously vital components. An effective compliance program is best thought of as a process. Circular in nature, it has a distinct beginning, but no end. Each time through the cycle, imperfections are uncovered, compliance risks exposed, policies and procedures revised and your company becomes that much closer to compliance perfection (illusive though that may be).

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Does Your Company Have Leaky Plumbing?

posted in: Thoughts | 0

In many ways the policies and procedures that make up your compliance program are analogous to the plumbing in your house. It is not something you typically spend much time thinking about, but if not designed for your specific requirements, professionally installed and quickly fixed when problems arise, you could literally be up to your neck in well, crap.

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Observations from SEC Cybersecurity Exams

posted in: News | 0

Recently the SEC recently concluded its second cybersecurity exam initiative of investment advisers, broker-dealers and investment companies. The examinations focused on the firms’ written policies and procedures regarding cybersecurity, including validating and testing that such policies and procedures were implemented and followed.

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