Compliance Program Implementation: Compliance Calendars and Testing

Once an adviser has established a compliance program with appropriate policies and procedures, it must implement that program effectively. An ACA Group presentation that is part of its ongoing “Building a Gold Standard Compliance Program” focused on two important elements of program implementation: compliance calendars and compliance testing. The program, which featured ACA Group’s Cari Hopfensperger, director, and Jaqueline Hummel, director of thought leadership, explored creating a compliance calendar; assigning responsibility for compliance; identifying common test areas; using trade blotters and other available information for testing; incorporating testing into the annual compliance review; and embedding compliance throughout an organization. This article synthesizes their insights. See our three-part series on tailoring a compliance program: “Why Fund Managers Should Customize” (Jul. 16, 2020); “What Fund Managers Should Consider” (Jul. 23, 2020); and “When Fund Managers Should Review and Update” (Jul. 30, 2020).

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