2016: Tackling a New Year, New Budgets, and the SEC’s Same Aggressive Pressures on Compliance

January 27, 2016

Super Bowl 50 is less than two weeks away, and as every NFL team knows, victory isn’t possible without the support of those both on and off the field. The U.S. Securities and Exchange Commission’s (“SEC”) 2016 Examinations Priorities include the same thematic areas as 2015, and we do not expect the aggression it showed in 2015 to diminish in 2016 when it comes to reviewing and enforcing its priorities. Unfortunately, many advisers struggle with balancing aggressive examination tactics, routine regulatory and investor inquiries, ever-shrinking budgets, and staff turnover in compliance, operations, back-office, and other departments generally considered to be the cost centers of a firm. These budget restraints, coupled with relatively flat market performance in 2015 and extreme volatility to date in 2016, are placing intense pressures on investment advisers, private fund managers, and other large and diversified financial institutions. This season, let ACA Compliance Group (“ACA”) manage your compliance blocking and tackling while you lead your compliance program to victory.

ACA provides investment advisers, broker-dealers, and other financial institutions with market-leading, unparalleled compliance expertise that can enhance a compliance program during times of resource constraints that might otherwise diminish the program’s effectiveness. During these times, outsourcing certain compliance initiatives can allow senior compliance professionals to focus on higher risk areas within an organization. That’s where ACA’s deep bench of professionals can step in and assist your firm, whether by helping to manage low-hanging, back-burner responsibilities, or by serving in a more senior role during a time of staffing changes.

ACA’s current outsourcing capabilities are substantial and evolving. We can help with a variety of routine and complex compliance initiatives that include, but are not limited to:

  • short-term and full-time secondments and staffing assistance;
  • electronic communication reviews;
  • high-volume marketing and advertising reviews;
  • monitoring of employees’ personal securities trading;
  • updating compliance logs, including gifts, entertainment, and political contributions logs;
  • reviewing employees’ outside business activities;
  • testing trade blotters for allocation issues, unusual commissions, trading errors, principal trades, cross trades, and other concerns;
  • conducting OFAC/SDN checks of employees, clients, and investors;
  • performing Internet searches to identify social media compliance and marketing issues as well as unreported political contributions; and
  • assisting with compliance-related special products.

The ACA team is available on an as-needed or full-time basis to provide support whenever you need it. Let us help you quickly and accurately complete your compliance to-do list with a high level of confidence and success, all with limited-to-no oversight. We’d like to share with you a few examples of ACA’s outsourcing capabilities. Please contact Greg Mekanik at (804) 379-7800 or Alan Halfenger at (617) 589-0904 if your firm needs assistance with its compliance responsibilities.