On January 16, 2014, The Investment Company Institute ("ICI") released an updated framework for Financial Intermediary Controls and Compliance Assessment Engagements ("FICCA")1. The original framework, developed in 2008, provided guidance for investment companies related to their oversight of the financial intermediaries through which they distribute their products; specifically applicable to omnibus relationships. The framework contains seventeen recommended areas of oversight, from management reporting and risk governance, to processing and technology.
The most recent update to the framework contains several noteworthy improvements. Primary changes include: