Properly trained compliance professionals are essential to the success of a compliance program, and dedicated internal compliance staff is hard to come by.
Rule 206(4)-7 under the Advisers Act requires an SEC-registered investment adviser to appoint a Chief Compliance Officer who is competent and knowledgeable regarding the Advisers Act and empowered with full responsibility and authority to develop and enforce appropriate policies and procedures for the adviser. State registered investment advisers are required to appoint someone responsible for the supervision and compliance of the adviser.
FINRA Rule 3130 requires FINRA-registered firms to designate and identify on their Form BD one or more principals to serve as a Chief Compliance Officer. Many other advisers and financial services firms have a business preference to formalize their operations and appoint someone to a fractional compliance or supervisory role.
All too often, investment advisers and other financial services firms hastily fill a vacant compliance position, to their detriment. Fractional resources can be particularly helpful in two situations:
Coast to Coast Compliance understands that firms experience urgent situations that create an immediate need to fill a vacancy, and our goal is to provide a flexible alternative. We provide a seasoned compliance professional to serve in an executive role, such as Chief Compliance Officer or Compliance Officer, or to serve as an additional resource. Engagements can be structured on a temporary, interim, or fractional basis depending on the specific needs of the firm.
An outside CCO also removes the conflict of a revenue-generating principal grading their own program, which pairs well with an independent annual compliance review. To discuss coverage, contact us.
Common questions about working with a securities compliance consulting firm.
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