A risk-based compliance program involves an explicit overlay of the client business model (products and services offered, client markets served, and product and service delivery channels) with the regulatory regime. We commence all client engagements with executive interviews to gain a full understanding of the firm’s needs. Documentation review is executed using an offsite or onsite protocol, at the direction of the client. We identify compliance gaps and collaborate with each client to close the gaps.
Step 1: Understand all aspects of our client’s business model relative to compliance, including:
- organizational structure
- professional expertise
- product and service offerings
- product distribution capabilities
- third party affiliations and service provider relationships
Step 2: Assess the efficacy and reliability of the compliance culture and dedicated compliance resources, including:
- registration and training protocol
- marketing and client service models
- communications and disclosures pursuant to fiduciary responsibilities
- portfolio and trade management practices
- integration of the compliance regimen with operational processes
- formal delegation of compliance responsibilities to firm personnel
Step 3: Identify inherent and prospective compliance and reputation risks, gaps, and deficiencies in light of current regulatory requirements and industry best practices.
Step 4: Deliver a compliance findings and recommendations report which is supported by regulatory rationale.
Step 5: If needed, escalate service offerings to include field audits, compliance program content development, staff training, and related implementation assistance as necessary to attain full compliance.
Step 6: Work with the CCO and business leaders to develop an ongoing compliance support engagement tailored to the unique needs of the firm.