One year after assuming their new roles, chief compliance officers at mutual fund advisory firms shouldn't expect to be off the hot seat anytime soon. There are still policies and procedures to review, update and expand upon where gaps are found; reports to generate; compliance checks and balances to assess; and a myriad of other unforeseen issues.
Moreover, the first rush of annual reviews, which the Securities and Exchange Commission mandated that CCOs and their staff formally conduct each year, is expected to occur this coming March and April. This is because the SEC required advisory firms to undertake their first annual reviews no later than 18 months after adopting compliance policies and procedures. For many investment companies whose boards formally approved their funds' new compliance policies just over one year ago, that review window is quickly approaching.