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Recent regulator guidance has reinforced a consistent message: compliance programs must do more than exist on paper. This article highlights key areas for CCOs to review, including KYC/KYP and suitability, conflicts of interest, documentation, marketing, cybersecurity, third-party oversight, training and compliance testing.

You are the UDP, president, CCO, or all of these, for a portfolio management firm with fewer than 5 advisors. You have concluded that you...

CASES HIGHLIGHTED: LACK OF SUFFICIENT KYC INFORMATION / UNSUITABLE RECOMMENDATIONS / FAILURE TO SUPERVISE This bulletin presents a...