With the COVID-19 Pandemic, a new presidency, and the announcement of SEC Chairman Jay Clayton’s departure, changes are expected to how the SEC will pursue and enforce potential regulatory and compliance violations.
Civil penalties, which recently have been considered ‘lighter,’ may soon shift to heavier penalties to deter company laxity in enforcement of policies and procedures and remind companies of the importance of having a workplace with strong compliance practices. Be aggressive with your annual compliance program reviews to avoid non-compliance penalties.
The SEC notes that misuse of material non-public information, especially when obtained through persons holding multiple roles in a Firm, can lead to violations of the Advisers Act. By having an independent third-party complete a policies and procedures review, areas of risk to prevent information mishandling can be identified, addressed, and reflected in your firm’s updated policies and procedures - before any risks become problematic.
Coast to Coast Compliance can conduct a comprehensive review of the consistency and adequacy of your firm’s policies and procedures, as well as the completeness and effectiveness of its overall compliance program.