With less than three months of the year remaining, compliance professionals are feeling the pressure to cross off those final to-do’s for 2019 and build a strong foundation for 2020.
To get firsthand insight on the challenges CCOs face, we sat down with one of ACA’s newest senior principal consultants and former CCO, Leigh Emery, to chat about the year-end obstacles, how to overcome them, and what trends to prepare for in 2020.
During our chat, Emery noted that, “Being CCO doesn’t mean every compliance task needs to fall to you, but it does mean you’re ultimately responsible for the firm’s compliance program supervision, so it’s important to know where you really need to be involved and where you can rely on others or implement software to save you time and energy.”
What should CCOs be prioritizing over the next few weeks?
Together we discussed the top five tasks compliance officers should focus on before year-end - below is summary of the key points we discussed.
- Outline your budget and resource allocation for the upcoming year
Review what worked and what didn’t this year. How will you work outsourcing or automation costs into your budget for next year to save you time and ultimately money as you scale your compliance program?
- If you haven’t yet, complete your annual review
It is required to be done annually so if you haven’t already, you’ll want to wrap it up and consider adjusting the timing of your annual testing for 2020 (it doesn’t have to be done at year-end). Additionally, don’t forget to document a test of your business continuity and disaster recovery plan.
- Start gathering data for your annual filings
Assuming your fiscal year end is December, form a project plan to get your amendments to Form ADV and/or Form PF filed. Data gathering can be the most painful point – put a plan in place now to avoid that.
- Wrap up Q4 compliance tasks and plan for urgent Q1 tasks
For example, if you need to complete your annual employee policy or code attestations, trading or holdings reports, etc. Think about how and when will you deploy, collect, and track these tasks. Do you need buy-in from anyone ahead of the holidays to get these things done on time.
- Complete a full read-through of your compliance policies and procedures
While the annual review is required to cover the adequacy and effectiveness of these policies, a cover-to-cover read of these documents is helpful to both to re-familiarize yourself with the content as you start the new year, and to flag items for testing or cleanup when you next amend the documents.
Listen to our complete interview here:
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How ACA Can Help
As you wrap up your 2019 compliance tasks and undergo your 2020 planning process, we’re here to help. Our team has significant experience in helping firms supplement their internal testing efforts and meet annual deadlines.
Need extra hands on deck to make your day to day easier? Our compliance support managed services provide a scalable option, involving little to no ramp up, allowing clients to control the variable cost.
Ready to ditch the spreadsheets? Our ComplianceAlpha® software platform helps firms automate manual tasks, identify risk through enhanced surveillance capabilities, derive deeper insights through connected data, simplify the submission of requests and disclosures for employees, and free up valuable time for more strategic, higher-value tasks. Request a demo here
To learn more, please reach out to your ACA consultant or request that a member of our team contact you directly here.
Leigh Emery is a Senior Principal Consultant based in Morristown, NJ. Prior to joining ACA as a Senior Principal Consultant, Leigh held a number of compliance and operational roles, most recently serving as Chief Compliance Officer for Dynasty Financial Partners, a New York based service platform for RIAs collectively managing more than $35 billion. Leigh has assisted hundreds of investment advisers with their compliance needs, including SEC registration, compliance program implementation and execution, and assistance with SEC and NFA examinations. Leigh received her B.S. in Business Management from the University of Phoenix, a post baccalaureate Certification of Professional Achievement in Business (Finance) from Columbia University, and her M.S. in Jurisprudence (Financial Services Law) from the Seton Hall University School of Law. Leigh has also earned the IACCP® designation (Investment Adviser Certified Compliance Professional®)