Investment advisers often have robust compliance testing programs in place to ensure their staff and control environment remain a well-oiled machine. Most of the time, such testing programs are front of mind and on top of the daily, weekly, or monthly to-do list. Yet 2020 – where compliance professionals are working from home during a global pandemic that comes with additional family obligations, enhanced day-to-day surveillance of staff, and adapting to changing expectations – isn’t a typical year.
Unfortunately, the obligation to forensically test and/or stress test your compliance program remains. In response to COVID-19 related challenges, 35% of surveyed firms deferred their compliance testing to 2H 2020, according to polling results captured on an ACA webcast during the height of the pandemic.
As we approach the end of the year, we understand that many firms are in a pinch to get their testing completed. To help you get started, we’ve developed an action plan to guide you through the key questions to ask as you get started on your existing testing plan or developing one.
This list is not intended to be exhaustive; testing should always be tailored to your firm’s specific risks.
How ACA Can Help
If you've fallen behind on your annual testing mandate or need help getting started, ACA’s team can help determine testing needs, perform testing, analyze the results, and determine the best path forward if enhancements are needed.
Failing to meet testing mandates can subject a firm to regulatory exposure by allowing mal- or misfeasance to continue unnoticed, and invite scrutiny from regulators, internal governance functions, and investors alike. ACA has significant experience in helping managers of all sizes to supplement their internal testing efforts and meet annual deadlines.
For questions or to discuss how ACA can help your firm strengthen its testing program, complete your testing requirements, and ensure your regulatory obligations are met, reach out to your ACA consultant or contact us here.