Here we are, one full year after the Securities and Exchange Commission adopted a new compliance program through Rule 38a-1 under the Investment Company Act of 1940, requiring fund boards to adopt written compliance policies and procedures reasonably designed to prevent violations of the federal securities laws by fund complexes, including compliance oversight of certain service providers.

Even a full year later, the industry arguably is not any more knowledgeable about the SEC's expectations than when the rule was adopted. That is because, in many respects, Rule 32a-1 is a mere skeleton to which a mutual fund board and its chief compliance officer must add muscle and flesh to make it a living, breathing constitution of principals and standards of conduct for the fund and its service providers.

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