A guide for chief compliance officers of registered investment advisers on how to develop, conduct and maintain an effective and robust annual testing programme

Every investment advisory firm is unique. Each has a different organisational structure, strategy and service offering and different operational approaches, personnel dynamics and company cultures. There is only one thing I can think of that is consistent from firm to firm: every investment adviser that is registered with the Securities and Exchange Commission (SEC) has to adhere to the same set of rules and regulations. Under Rule 206(4)-7 of the Investment Advisors Act, advisers are required to maintain policies and procedures, conduct an annual review to support those policies and procedures, and designate an individual at the firm as a chief compliance officer (CCO) to administrator the policies and annual review, often referred to in its entirety as a compliance programme. Accomplishing the task of this compliance programme can feel daunting considering that the SEC’s rules and regulations are vast, intricate and confusing. With this in mind, I developed a methodology for tackling the annual compliance review that — time and time again — has made my clients’ jobs easier. This approach is based on simplicity, practicality and customisation. I use it with every one of our clients. And it is my goal to share it with every new, newish and multi-hatted CCO to help make their lives easier.