Emerging Investor Issue – Compliance Program Transparency
In 2016, the competition for institutional investor allocations continues to intensify.
As part of this competition, many asset managers face a NEW hurdle: “Compliance Program Transparency™.”
Previously, asset managers could satisfy a due diligence inquiry regarding their compliance program with either:
- A short meeting about the compliance program
- Furnishing the Table of Contents from the compliance manual
- An onsite review of the compliance manual
Unfortunately, the escalating enforcement environment creates an even greater “head line” risk for investors, which supersedes investment return.
Consequently, an increasing number of investors have requested more substantive and documented access to a firm’s compliance program.