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SEC’s Concerns Prod a Rethinking of Outsourced Compliance

Joe Mont | December 8, 2015

Faced with budget constraints and a shallow talent pool, financial firms frequently turn to external professionals to supplement, if not entirely run, their compliance programs. Updating firm policies and procedures, preparing regulatory filings, and conducting annual compliance reviews are just some of the services increasingly farmed out to external consultants and law firms.

That trend has caught the attention of the Securities and Exchange Commission, which recently sounded a warning. The question now asked by many is whether a Nov. 9 risk alert issued by the Office of Compliance Inspections and Examinations was intended to push firms that outsource the role of chief compliance officer away from the practice or, instead, creates the equivalent of a safe harbor for doing so by further clarifying a regulatory view of what a robust program must exhibit.


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