Compliance Training 101

Although hedge fund managers must have compliance programs, neither Rule 204(4)‑7 under the Investment Advisers Act of 1940 – the Compliance Rule – nor its adopting release states that managers must provide training on their compliance programs. Without proper training, however, employees will not know what the manager’s policies and procedures are or how to comply with them. Moreover, the SEC clearly expects managers to provide compliance training. The first article in a two-part series explains the SEC’s expectations as to compliance training and provides three traps to avoid as to the substance of a fund manager’s training. The second article discusses who conducts the compliance training and identifies five traps to avoid when providing training. See “High- and Low-Tech Innovations for Fund Managers to Overcome Compliance Training’s Drawbacks” (Feb. 1, 2018); and “Early and Often: Compliance Training Pays Big Dividends for Private Fund Advisers” (Jul. 8, 2009).

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