United States: 2022 Investment Management Regulation and Compliance Calendar and Guide
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As we enter the new year, it is important that investment managers, private funds, commodity pool operators and other investment management professionals consider the range of regulatory requirements they face. to respect. We hope that this Regulatory and Compliance Calendar and accompanying documents will be a useful tool in managing compliance requirements throughout the year.
When evaluating your 2022 compliance strategy, it’s important to keep in mind not only individual requirements and best practices, but also the broader themes defining the regulatory and enforcement environment. These themes should be considered by advisors in light of the operational and compliance challenges they have faced, including the continuing COVID-19 pandemic, and how they have modified their compliance programs to adapt to these changes. In our view, last year’s enforcement actions and SEC risk alerts continue to send three clear messages:
- Transparency is a priority. The SEC takes prompt action in cases where there is a lack of required disclosure or a conflict of interest, and in cases where an investment manager has made a material misrepresentation. Companies should strive to be scrupulously transparent in their arrangements and dealings.
- Policies and procedures are just the start. Companies must have a solid infrastructure that translates policies and procedures into actions and behaviors. This includes appropriate and timely controls, internal audit functions and escalation protocols. In addition, firms must act and follow policies and procedures in a manner that reasonably ensures compliance with such policies and procedures and applicable law.
- Compliance must be approached holistically. Compliance procedures cannot be applied in a ticked manner. Companies should implement a risk-based approach, guided by thorough due diligence of customers, employees and suppliers.
Companies and managers who follow rigorous application of requirements while keeping an eye on major trends will be well positioned to avoid the tangible and intangible costs that come with compliance failures.
Download: 2022 Investment Management Regulation and Compliance Calendar and Guide (pdf)
The content of this article is intended to provide a general guide on the subject. Specialist advice should be sought regarding your particular situation.
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